Читать книгу Global Tax Governance. Taxation on Digital Economy, Transfer Pricing and Litigation in Tax Matters (MAPs + ADR) Policies for Global Sustainability. Ongoing U.N. 2030 (SDG) and Addis Ababa Agendas онлайн

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It is thus crucial to identify some of the most pressing international tax questions arising in the “new-normal” and to propose an approach for a possible response. In particular, great focus should be placed on the issues of transfer pricing and of permanent establishment. As such, a case-by-case approach shall be essential for multinationals, to mitigate tax risks. Moreover, a way out of the crisis demands a long-term and coordinated approach at the supranational level.

To face the health and economic crisis, national governments introduced lockdown measures, prohibiting or largely limiting manufacturing activities, restricting transport and imposing rigid and long quarantine periods for physical persons. For multinational enterprises, the new restrictive context for the performance of business activities questions their established transfer pricing policies. In addition, there is a clear risk for recognition of borderline permanent establishments at the place where employees have been restricted to (tele)work.