The Interpretation of Multilateral Instruments and the Status of Commentary: The Definition of “Permanent Establishment” in the GLoBE Pillar Two Model Rules

Journal
International; OECD
Bulletin for International Taxation 2025 (Volume 79), No. 2
This article explores the growing reliance on interpretative texts accompanying international tax instruments, focusing on the GloBE Pillar Two Model Rules. It advocates a rules-based approach to ensure alignment between such texts and original provisions, analysing interpretation challenges and implications for legislative practice and consistency in application.