The permanent establishment (PE) concept is a core element of the global international tax framework. With increasing cross-border business activities resulting from the globalization of the world economy, the PE risk is taking center stage among international tax issues. At the same time, the attribution of profits to PEs becomes more complex due to new business models, ecosystems and integration of operations within a business model. However, the attribution of profits to PEs also gains particular importance for the ramifications that it will have on the Global Anti-Base Erosion (GloBE) rules calculations when applicable.
Source EY
