As a fundamental concept in determining the tax liability of multinational enterprises (MNEs) operating in foreign jurisdictions, understanding the intricacies of PE is crucial for businesses looking to navigate the global tax environment. As globalization continues to shape the business landscape, the importance of understanding the nuances of PE cannot be overstated. The concept, which has evolved over the years, determines whether a company has a taxable presence in a particular jurisdiction and also is central to the allocation of taxing rights between countries. This issue explores the new rules of Pillar Two and their impact on PEs, the implications of new ways of working remotely, controversy, and the latest status of the Multilateral Instrument. Additionally, we will review recent PE cases and developments and their impact on businesses.
Source EY
