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

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
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article

The Interpretation of Multilateral Instruments and the Status of Commentary: The Definition of “Permanent Establishment” in the GLoBE Pillar Two Model Rules

G. Jackson
Bulletin for international taxation
Taxation and Legal Issues
article

The Interpretation of Multilateral Instruments and the Status of Commentary: The Definition of “Permanent Establishment” in the GLoBE Pillar Two Model Rules

G. Jackson
article en

Abstract

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.

Bulletin for international taxationVol. 79(2)
Partnerships for the goals
Openalex Percentile: Top 98%
Taxation and Legal Issues
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The Interpretation of Multilateral Instruments and the Status of Commentary: The Definition of “Permanent Establishment” in the GLoBE Pillar Two Model Rules — G. Jackson · Bulletin for international taxation (2025) | TGRS Research Map | TGRS