The Anti-Avoidance Rule Regarding Permanent Establishments in Third Countries of the OECD/G20 Base Erosion and Profit Shifting Project: Is It Necessary?

In this article, the author considers the OECD/G20 Base Erosion and Profit Shifting Project as it affects permanent establishments (PEs) and third countries. Having examined the proposal, he concludes that the rule has several flaws, is difficult to apply and may not be necessary.