As in Newtonian physics, actions in tax law attract reactions. As global trade expands, so do the problems of monitoring the taxation of multinational enterprises (MNEs). Countries are eager to claim taxing jurisdiction over foreign corporations that operate within their borders as they provide revenues and cannot generate the political emotion that domestic persons muster.
Early on, the League of Nations recognized the propensity of governments to tax foreign corporations. Hence, they conceived the notion of the "permanent establishment" (PE) to restrain unwarranted taxation of foreign...
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Previously published in The Lawyer's Daily
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