From Ottawa to Lausanne: Much Done but More to Do?

Abstract

This mini‑track on e‑Tax and e‑Revenue coincides with the 10th anniversary of the landmark Ottawa meeting. Most concerns then related to widespread tax base erosion due, inter alia, to the anonymity of Internet activity, the high mobility of e‑business and the attraction of tax havens. Most, certainly not all, of these concerns have been allayed since but the debate as to what constitutes a Permanent Establishment (PE), and the level of attributable profits to such a PE, is ongoing. Using a case study scenario approach, I consider the tax issues which a typical MNC would encounter in seeking to reengineer its global activities. The conclusion highlights the need for more specific guidance in this area.