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Problems with the PE threshold

It's a common belief that the digitalization of business has challenged the taxing rights of market jurisdictions. Lowering the threshold for PE qualification and the introduction of Pillar One were the OECD's proposed solutions to this issue. But, is this presumption accurate? In the third webinar series on PE Problems by the Amsterdam Centre for Transfer Pricing and Income Allocation of the University of Amsterdam, Prof. Scott Wilkie (Osgoode Hall Law School at York University, Canada) will discuss the possibilities and impossibilities of taxing income generating activities in market jurisdictions under the old and new PE definitions. Although the webinar is not “about” Pillar One, it will play an important role in the discussion. This one-hour thought-provoking session with Prof. dr. Scott Wilkie, moderated by dr. Svitlana Buriak, provides ample opportunity for engaging discussions and Q&A. Expect us to address the following key topics: 🔶 What aspects of the PE definition highlight the perceived problems with the PE threshold? 🔶Are these PE threshold issues prescriptive or descriptive, and why does this distinction matter? 🔶Is the PE threshold a genuine challenge or merely a matter of interpretation? 🔶What does "carrying on business IN" mean when we remove the interpretational crutches? 🔶Can a dynamic interpretation of Article 5 of the OECD Model enable a more flexible attribution of taxing rights to market jurisdictions? 🔶Will the new definition effectively resolve the problems, and will Pillar One play a role in this resolution? 🔶...and, why DSTs are essentially a form of income taxation in its most conventional sense.