Beyond Borders: Practical Frameworks to Navigate Permanent Establishments and Profit Allocations in a Home Office Setting

Working abroad from home is a growing trend in today’s working landscape, which has not yet been reflected in the OECD Model. Therefore, this article proposes amendments to article 5 of the OECD Model to capture the establishment of home office PEs and also covers the profit allocation thereto. The recommendations made aim to find a balance between fair taxation, proportionality and simplification.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2025-04-22
DOI
https://doi.org/10.59403/yr48xw
Primary Topic
Housing Market and Economics
Type
article
Field-Weighted Citation Impact
0.00
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article

Beyond Borders: Practical Frameworks to Navigate Permanent Establishments and Profit Allocations in a Home Office Setting

L. Visscher
International Transfer Pricing Journal
Housing Market and Economics
article

Beyond Borders: Practical Frameworks to Navigate Permanent Establishments and Profit Allocations in a Home Office Setting

L. Visscher
article en

Abstract

Working abroad from home is a growing trend in today’s working landscape, which has not yet been reflected in the OECD Model. Therefore, this article proposes amendments to article 5 of the OECD Model to capture the establishment of home office PEs and also covers the profit allocation thereto. The recommendations made aim to find a balance between fair taxation, proportionality and simplification.

International Transfer Pricing JournalVol. 32(3)
Openalex Percentile: Top 88%
Housing Market and Economics
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Beyond Borders: Practical Frameworks to Navigate Permanent Establishments and Profit Allocations in a Home Office Setting — L. Visscher · International Transfer Pricing Journal (2025) | TGRS Research Map | TGRS