Taxation-Transnational Commons^™

Problems Involving Permanent Establishments: Overview Of Relevant Issues In Today’S International Economy, Leonardo F.M. Castro

Global Business Law Review

The present article analyzes the most common problems related to the Permanent Establishment (PE) concept in International Tax in current modern economy, after the booming of e-commerce, the consolidation of the globalization process, and the new attempts to update and improve such concept in double tax treaties. For that purpose, this article addresses the structure of Article 5 of the OECD Model Tax Convention and gives readers an overview of the concepts, definitions, and problems arising from each of the Article 5 paragraphs of such Model Convention. After such overview, it examines the hottest topics in today‟s international economy that …