Complex, fast-changing global business models, the growth of
the digital economy and the increasing number of companies with
internationally mobile staff have combined to force a
re-examination of the way tax is assessed on the profits of
companies with international operations.
It is important to note that PE should not be perceived as
"anti-cross border trade" and that businesses can manage
their PE risk legitimately by, generally speaking, adhering to
specific rules when operating in different jurisdictions.
The members of Alliott Group's International Tax Services
Group [
https://www.alliottgroup.net/international-tax-services-group/]
explain in this article the action under way at the global level
(in the form of implementation of the BEPS Action Point 7) to
provide greater clarity on what will be perceived as the artificial
avoidance of PE by foreign companies. Read on to find out why this
has implications for any business, large or small, that