Taxation of the Ride-Sharing Economy: Source Taxation through Service Permanent Establishment Provisions Revisited – The Case under the Argentine Treaty Network

Journal
Argentina; International; OECD
Bulletin for International Taxation 2019 (Volume 73), No. 12
This article considers the extent to which the application of the treaty Service permanent establishment provision would permit the source taxation of business profits derived by foreign ride-sharing platforms. In particular, the recently issued preliminary opinions of the Argentine tax authorities in this respect and the resulting request for a mutual agreement procedure are examined.