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07 February 2023 PE Watch: 2022 in review 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. Regarding the future of the PE concept, it is likely that it will continue to evolve in response to changes in the way businesses operate and the increasing globalization of the economy. For example, the rise of digital technologies and the increasing use of the internet for conducting business may lead to the development of new rules or interpretations of existing rules related to PEs. Overall, it is important for companies to stay up to date on PE developments, as failure to comply with the rules related to PEs can result in significant tax consequences. The objective of PE Watch is to provide you with valuable insights and practical guidance on PEs. Document ID: 2023-5148 |
