Do we need a new definition of Permanent Establishment for digital operations in Double Tax Treaties?

University essay from Lunds universitet/Institutionen för handelsrätt

Abstract: This master thesis investigates the need for a new Permanent Establishment (PE) definition for digital purposes in Double Tax Treaties (DTTs). In the core of the necessity to pursue the analysis of this, are the digital economic developments, and the challenges that they pose for international tax law, policymakers, countries, and businesses. More specifically, the physical presence of digitalized businesses, or the lack of it, in certain jurisdictions for tax purposes is of particular importance, because these create the difficulty for countries to retain their tax base.

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