Permanent Establishment 2.0 - Is It Time for an Update?

31 Pages Posted: 14 Sep 2017

Date Written: August 12, 2017


The development of technology has made businesses respond and adapt to the new conditions on the market. However, this could hardly be said for the applicable legislation at national or international level. The digitalization of the economy has managed to put to a test our understanding of concepts such as value creation and physical presence. The legal concepts which we work with today are not suitable to deal with the taxation of the profits of the digital enterprises. This is why the taxation of the digital economy is certainly an important issue that needs to be addressed. This paper will address the various challenges the digital economy has brought upon the field of taxation, will analyse and suggest possible solutions.

Keywords: permanent establishment, BEPS, internet of things, big data, OECD, paper, update, seat, server,physical presence, digital enterprise, value creation, taxation, article, tax

JEL Classification: K34

Suggested Citation

Atanasov, Atanas, Permanent Establishment 2.0 - Is It Time for an Update? (August 12, 2017). Available at SSRN: or

Atanas Atanasov (Contact Author)

KPMG Luxembourg ( email )

Avenue John F. Kennedy 39
Luxembourg, L-1855

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