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This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.
These proceedings represent the work of contributors to the 24th European Conference on Knowledge Management (ECKM 2023), hosted by Iscte – Instituto Universitário de Lisboa, Portugal on 7-8 September 2023. The Conference Chair is Prof Florinda Matos, and the Programme Chair is Prof Álvaro Rosa, both from Iscte Business School, Iscte – Instituto Universitário de Lisboa, Portugal. ECKM is now a well-established event on the academic research calendar and now in its 24th year the key aim remains the opportunity for participants to share ideas and meet the people who hold them. The scope of papers will ensure an interesting two days. The subjects covered illustrate the wide range of topi...
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