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February 10, 2021

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.


PE Watch | 2020 in review