This article is a reply to Martin Wichmann's reply from a German perspective to John F. Avery Jones's article 'Why Can't the English ... ?', both published in the Bulletin for International Taxation of the International Bureau of Fiscal Documentation (IBFD), 2019 (Volume 73), No. 6/7. It argues...

This article examines the impact of the international tax system on the location decision of a foreign permanent establishment (PE) including cross-border loss relief and activity clauses. Germany, e.g., operates a hybrid system of international taxation, under which foreign income from PEs...

Introduction -- Fundamentals and objective -- Source taxation of business profits according to the OECD model -- Source taxation of business profits from a national point of view of Germany, the US and the BRIC states -- Cross-country analysis of the OECD and national PE concepts and the rules...