Tax News Update    Email this document    Print this document  

February 10, 2021
2021-0308

PE Watch | 2020 in review

The permanent establishment (PE) concept is a core element of the global international tax framework. Its relevance has increased in 2020 due to globalization, digitalization of the economy, and the ease of carrying on business worldwide. Consequently, tax authorities have placed potential PEs under increased scrutiny.  As the international tax landscape continues to change, tax uncertainty will likely increase as governments respond to the health, economic and social threats of the COVID-19 pandemic. Moreover, tax transparency is expected to continue to expand, both by the introduction of new reporting requirements and the enhanced exchange and use of reported information by tax administrations. In an era where tax transparency is the norm, new business models and the complexity of tax systems are likely to result in increased controversy, including with regard to the determination of PEs.

This edition of EY’s PE Watch | 2020 in review, attached below, covers four PE topics: (i) controversy; (ii) BEPS multilateral instrument; (iii) domestic law; and (iv) COVID-19.

———————
ATTACHMENT

PE Watch | 2020 in review

 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 1996 – 2024, Ernst & Young LLP

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

EY US Tax News Update Master Agreement | EY Privacy Statement