Interpretative Issues Arising from the Definitions of Permanent Establishments under the GloBE Model Rules

Journal
Patti, G.F.
International; OECD
Bulletin for International Taxation 2024 (Volume 78), No. 3
Price USD 45

The GloBE Model Rules on Pillar Two contain certain specific definitions of permanent establishments, which apply depending on the features of the foreign place of business of a given enterprise. The definitions refer to treaty law, but the meaning and the effect of those references are not always entirely clear.