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February 10, 2021

PE Watch: 2020 in review

The permanent establishment (PE) concept is a core element of the global international tax framework. Its relevance has increased in 2020 due to globalization, digitalization of the economy, and the ease of carrying on business worldwide. Consequently, tax authorities have placed potential PEs under increased scrutiny.

Tax uncertainty will significantly increase as governments respond to the health, economic and social threats of the COVID-19 pandemic, with new tax measures sparked by a growing need for revenues. Moreover, tax transparency is expected to continue to expand, both by introduction of new reporting requirements and the enhanced exchange and use of reported information by tax administrations. In an era where tax transparency is the norm, new business models and the complexity of tax systems are likely to result in increased controversy, including with respect to the determination of PEs.

EY’s publication, PE Watch: 2020 in review, covers four PE topics: controversy, BEPS multilateral instrument, domestic law and COVID-19, and each topic has two sections. The first section provides background information while the second section addresses specific country developments during 2020 with respect to each topic.

Details and information can be found in the below PDF.


PE Watch: 2020 in review


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