Permanent Establishments Through Related Corporations Under the OECD Model Treaty
As global tax authorities tighten their grip on multinational enterprises, one contentious issue has taken center stage: can a subsidiary create a “permanent establishment” for its parent company? In Permanent Establishments Through Related Corporations Under the OECD Model Treaty, Matias Milet explores this complex and increasingly high-stakes question. Tracing the debate from the League of […]