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Some Comments on the Attribution of Profits to the Digital Permanent Establishment
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What this work says
Outgoing claims: the papers this work cites, builds on, or argues with.
inferredcites →https://doi.org/10.2139/ssrn.2591829openalex-snapshot
Blueprints for a New PE Nexus to Tax Business Income in the Era of the Digital Economy
inferredcites →https://doi.org/10.59403/15tknh7openalex-snapshot
Human Capital in Value Creation and Post-BEPS Tax Policy: An Outlook
inferredcites →https://doi.org/10.59403/1gh0kxnopenalex-snapshot
Addressing the Tax Challenges of the Digitalization of the Economy – A Possible Answer in the Proper Application of the Transfer Pricing Rules?
What points at this work
Incoming claims: where this work appears in other papers’ reference lists and arguments.
inferred← citeshttps://doi.org/10.2139/ssrn.3303530openalex-extracted
Perceived Fairness in the Taxation of a Digital Business Model
inferred← citeshttps://doi.org/10.51302/rcyt.2021.7381openalex-snapshot
El paradigma de justicia tributaria a través de nuevos tributos: ¿realidad o ficción?
inferred← citeshttps://doi.org/10.59403/15ze88nopenalex-snapshot
Digital Economy and Profit Allocation: The Application of the Profit Split Method to the Value Created by a “Significant Digital Presence”
inferred← citeshttps://doi.org/10.59403/1g1hrbaopenalex-snapshot
Taxation of the Ride-Sharing Economy: Source Taxation through Service Permanent Establishment Provisions Revisited – The Case under the Argentine Treaty Network
inferred← citeshttps://doi.org/10.59403/1kvnj3xopenalex-snapshot
(Mis)guided by the Value Creation Principle – Can New Concepts Solve Old Problems?
inferred← citeshttps://doi.org/10.59403/1msjp5c003openalex-snapshot
Chapter 3: User Contribution to Value Creation: The Benefit Principle in the Spotlight
inferred← citeshttps://doi.org/10.59403/1msjp5c004openalex-snapshot
Chapter 4: Taxation of the Digital Economy: A New Dawn for Multilateralism and Mutual Recognition
inferred← citeshttps://doi.org/10.59403/1msjp5c006openalex-snapshot
Chapter 6: Solving the Allocation of Taxing Rights Debate for the Digitalized Economy: Shortcomings of the Digital PE Proposal and Reconsideration of the Base-Eroding Payments Proposal
inferred← citeshttps://doi.org/10.59403/1msjp5c014openalex-snapshot
Chapter 14: The Blockchain Revolution for Transfer Pricing Documentation: If Not in 2020, Then When?
inferred← citeshttps://doi.org/10.59403/1vkve22009openalex-snapshot
Chapter 9: Pillar Two and Transfer Pricing
inferred← citeshttps://doi.org/10.59403/1xneffvopenalex-snapshot
Profit Attribution Challenges in a Digital Economy – A Transfer Pricing Analysis of the EU Virtual Permanent Establishment Concept
inferred← citeshttps://doi.org/10.59403/23jw9emopenalex-snapshot
Article 5: Permanent Establishment - Global Tax Treaty Commentaries (Last reviewed 1 September 2020)
inferred← citeshttps://doi.org/10.59403/259j6nbopenalex-snapshot
Virtual Real Estate in the Metaverse: How Should Countries Allocate Taxing Rights?
inferred← citeshttps://doi.org/10.59403/2ngncvgopenalex-snapshot
Article 5: Permanent Establishment - Global Tax Treaty Commentaries (Last reviewed 1 October 2018)
inferred← citeshttps://doi.org/10.59403/2zrp0eyopenalex-snapshot
Article 7: Business Profits - Global Tax Treaty Commentaries (Last reviewed 1 January 2023)
inferred← citeshttps://doi.org/10.59403/32gp8n9openalex-snapshot
Article 5: Permanent Establishment - Global Tax Treaty Commentaries (Last reviewed 1 September 2022)
inferred← citeshttps://doi.org/10.59403/32jh6qtopenalex-snapshot
Article 5: Permanent Establishment - Global Tax Treaty Commentaries (Last reviewed 1 October 2024)
inferred← citeshttps://doi.org/10.59403/33xqaxnopenalex-snapshot
The Data Economy: On Evaluation and Taxation
inferred← citeshttps://doi.org/10.59403/3e4qh0dopenalex-snapshot
Article 7: Business Profits - Global Tax Treaty Commentaries (Last reviewed 12 July 2025)
inferred← citeshttps://doi.org/10.59403/3xrxy0dopenalex-snapshot
Taxing Data-Driven Business: Towards Data Point Pricing
inferred← citeshttps://doi.org/10.59403/3z734hjopenalex-snapshot
Article 5: Permanent Establishment - Global Tax Treaty Commentaries (Last reviewed 1 July 2026)
inferred← citeshttps://doi.org/10.59403/d4pfa5005openalex-snapshot
Chapter 5: Taxing the Dependent Agent Permanent Establishment in the State of Source: What Has Been Achieved through the Modifications to Article 5?
inferred← citeshttps://doi.org/10.7256/2454-065x.2025.1.72942openalex-snapshot
The concept of monitoring the tax risks of the state in the context of the digital economy
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