In this episode of Taxed Out, Vanja Podinic and Colin Little explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment (PE), transfer pricing, intangible licensing and anti-avoidance, and how digitalised business models challenge traditional concepts like “fixed place of business”.

The conversation highlights the pressure points and divergent international approaches and practical takeaways. To hear future episodes of Taxed Out, subscribe via your preferred podcast platform or visit ashurst.com/podcasts.

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