Addressing Hybrid PE Mismatches: The Guidance of the Code of Conduct Group

Journal
Gil García, E.
European Union
European Taxation 2017 (Volume 57), No. 2/3
PriceUSD 45

This note addresses hybrid permanent establishment (PE) mismatches involving third countries. The author examines the McDonald’s case, an example of a hybrid PE scenario, in the context of recent guidance approved by the Code of Conduct Group.