With the ever evolving digitisation of business solutions and cyberisation of the workplace, the Finance Act 2020 has finally consigned the concept of Permanent (PE) Establishment to the bin and used Significant Economic Presence (SEP) to shatter artificial constructions intended to avoid tax liabilities due to non-residency. Beyond this, there is also the issue of attribution of profits between source and residence states which relies on tax treaties to evade double taxation and non-taxation and the issue of characterisation of income.
Source SSRN
