Permanent Establishment in Digital Economy: Is Human Element Relevant?

In the current age of digital economy, robots and remotely-operated computerized equipment are gradually taking over many work sites. In near future, in many cases, a ‘fixed place of business’ (a prerequisite for existence of a permanent establishment) may be operated entirely without human involvement at the work site. For instance, an enterprise could produce goods in a foreign country (Source State) in a ‘lights-out factory’. Wikipedia defines “lights-out factories” as factories that are “fully automated and require no human presence on-site”.

Source Dr Amar Mehta Ph.D, LL.M, ACA

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