The Challenge of Identifying Management Permanent Establishments

Journal
Germany
European Taxation 2025 (Volume 65), No. 2/3
In this article, the author examines the topic of management permanent establishments (PEs). The article comments on current discussions surrounding identifying management PEs and provides an overview of recent decisions of the German tax courts. The author concludes that the identification of the preconditions for a PE remains difficult despite a recent amendment to the administrative guidelines.