Show Notes
In this episode Grahame and Harriet tackle the thorny issue of the role of the permanent establishment in Pillar 2.
After a recap as to the use of permanents establishments in domestic and treaty law, and some pointless (and edited out) bickering they draw the conclusion that the Pillar 2 definition of Permanent Establishment deviates somewhat from a pure form and will take some time to settle down.
The definition of PE in Pillar 2 is vitally important for helping not only to identify MNEs but also to help with the calculation of the relevant effective tax rates across the globe. of
More from International Tax Bites
In this our 100th Episode Harriet and Grahame tackle the recently released draft of the UN's First Protocol on the Taxation of Cropss Border Services. They tackle the document head on and discuss the new and some not so new concepts that it introduces to international taxation. As ever they seek to look through the hype at what the docuemtn actually says and examine whether it really is a matter of substance or an early draft that requires quite a lot of work.
In this the first of a two part episode Harriet and Grahame discuss the Zero Draft Framework Convention on International Tax Cooperation which has been produced byt he UN at their July meeting on international tax cooperation. The document sets out its objectives and principles and establishes the framework which will be fleshed out in later protocols. Harriet and Grahame discuss the tax credibility of the document in general, the process and stakeholders which have been consulted and whether much of what is covered is already being done succesfully by the OECD.
In this the 98th episode of International Tax Bites, Harriet and Grahame discuss the OECD Side by Side Package which introduces a number of Pillar 2 related provisions which are not all related to the US.
In this episode Harriet and Grahame complete their review of the 2025 revisions to the OECD Model Convention commentary on permanent establishments. This episode sees them discuss the changes to the Commentary around extractive industries whether onshore or offshore.
In this episode Harriet and Grahame discuss the recent changes to the OECD Commentary on the Model Double Taxation Convention which expands the thinking around working from home and what constitutes a permanent establishment.