Companies are spending an increasing amount of time on managing the existence of – and the allocation of income to – permanent establishments. Often, several departments are involved in dealing with potential exposures or using some of the opportunities to structure their organisation more effectively. The change in the way companies operate their businesses globally adds to this complexity and raises new questions, which were not necessarily anticipated when international law concepts were initially developed. Although there are some recent policy developments, it remains uncertain whether these will resolve the most pressing concerns.
This report provides an overview of some of today’s main trends regarding the topic of permanent establishments.