Digital Permanent Establishment

Abstract

The permanent establishment (PE) has always been of interest in the field of international taxes in the taxation of profits of foreign enterprises in the source state. Over the years, the PE concept has undergone a number of changes. Their manifestation is reflected both from theoretical and practical perspective in connection with the variety of cases on this matter. Over the last years, the idea of digital PE has been subject of discussion both at worldwide and at European level. The current study analyzes the possibility of its introduction through the double tax treaties (DTTs) and the European Union law (EU law). In this regard, the measures undertaken in the legislation of different states are also examined.