The Interpretation of Multilateral Instruments and the Status of Commentary: The Definition of “Permanent Establishment” in the GLoBE Pillar Two Model Rules
This article explores the growing reliance on interpretative texts accompanying international tax instruments, focusing on the GloBE Pillar Two Model Rules. It advocates a rules-based approach to ensure alignment between such texts and original provisions, analysing interpretation challenges and implications for legislative practice and consistency in application.
Authors
- G. Jackson
Publication Details
- Journal
- Bulletin for international taxation
- Published
- 2025-01-22
- DOI
- https://doi.org/10.59403/5mh097
- Primary Topic
- Taxation and Legal Issues
- Type
- article
- Field-Weighted Citation Impact
- 0.00