The relevance of the commentaries on the OECD and UN models for the interpretation of the UN model /David Orzechowski --Business profits, permanent establishments and associated enterprises /Raffaele Petruzzi and Viktoria Wöhrer --Independent and dependent personal services /Benjamin Walker and...

Tax policy has always been a predominant element of national economic policies and a decisive tool in directing the actions of governments in the economic field. In the past decade, however, as an increasingly globalized economy has presented challenges, tax policy has gained new importance...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

The Organization for Economic Cooperation and Development (OECD) under Base Erosion and Profit Shifting (BEPS) Action 2 indicated that tax arbitrage via hybrid mismatch arrangements “result in a substantial erosion of the taxable bases of the countries concerned” and “have an overall...