SWI 2018, 476
Permanent establishments (PEs) are subject to discussion, both at the international and the national level, ever since the term has been introduced. In the first half of the year 2018, the Austrian Ministry of Finance published several legal opinions concerning PEs. Meanwhile, the European Commission proposed two guidelines seeking to ensure fair taxation of digital business activities. In the following, Domenic Dirnbacher takes a close look at the most recent developments on PEs with regard to force of attraction (cf Art 7 OECD MC), power of disposal, permanent facility, auxiliary PEs, and digital PEs.