Permanent Establishments under the Pillars: The Relevance of a Transfer Pricing Analysis
Permanent Establishments under the Pillars: The Relevance of a Transfer Pricing Analysis

Summary/Abstract: This paper analyses the treatment of Permanent Establishments (PEs) under the OECD’s Pillar One and Pillar Two frameworks. It delves into the complexities of the Global Anti Base Erosion Model Rules (GloBE) and the Qualified Domestic Minimum Top-Up Tax (QDMTT) rules under Pillar Two, as well as the reallocation of taxing rights under Pillar One. The role of transfer pricing in dealing with PEs is scrutinised, particularly its influence on the calculation of Adjusted GloBE income and Elimination Profit. The practical implications of these rules on PEs are illustrated through case studies. The paper also highlights the potential for disputes and the need for upfront certainty on transfer pricing positions.

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