{"title":"Interpretative Issues Arising from the Definitions of Permanent Establishments under the GloBE Model Rules","authors":"G.F. Patti","doi":"10.59403/1rcq0sf","DOIUrl":null,"url":null,"abstract":"The GloBE Model Rules on Pillar Two contain certain specific definitions of permanent establishments, which apply depending on the features of the foreign place of business of a given enterprise. The definitions refer to treaty law, but the meaning and the effect of those references are not always entirely clear.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"54 3","pages":""},"PeriodicalIF":0.0000,"publicationDate":"2024-02-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"0","resultStr":null,"platform":"Semanticscholar","paperid":null,"PeriodicalName":"Bulletin for International Taxation","FirstCategoryId":"1085","ListUrlMain":"https://doi.org/10.59403/1rcq0sf","RegionNum":0,"RegionCategory":null,"ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"","JCRName":"","Score":null,"Total":0}
引用次数: 0
Abstract
The GloBE Model Rules on Pillar Two contain certain specific definitions of permanent establishments, which apply depending on the features of the foreign place of business of a given enterprise. The definitions refer to treaty law, but the meaning and the effect of those references are not always entirely clear.