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 Nations to modern OECD guidance, and through landmark UK and Canadian cases, the paper reveals how the thin line between corporate separateness and economic reality continues to shape who gets to tax the profits of multinational groups. Read the full article here.