Legislation should be amended, if necessary, to ensure MNEs do not face undue hardship.

This article examines the ruling of the Supreme Court in Morgan Stanley and the ramifications of that case for the interpretation of the treaty article on permanent establishments and the attribution of profit to a permanent establishment in an international context.

This article examines the ruling of the Supreme Court in Morgan Stanley and the ramifications of that case for the interpretation of the treaty article on permanent establishments and the attribution of profit to a permanent establishment in an international context.