In this episode Grahame and Harriet tackle the thorny issue of the role of the permanent establishment in Pillar 2.

After a recap as to the use of permanents establishments in domestic and treaty law, and some pointless (and edited out) bickering they draw the conclusion that the Pillar 2 definition of Permanent Establishment deviates somewhat from a pure form and will take some time to settle down.

The definition of PE in Pillar 2 is vitally important for helping not only to identify MNEs but also to help with the calculation of the relevant effective tax rates across the globe. of