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Working Papers

To Be or not B(2B)? The question is about the (sub)digital P(F)E

The Lisbon International and European Tax Law Seminars - nº2 - Stoycho Dulevski

Challenges regarding the permanent establishment’s (PE) and fixed establishment’s (FE) legal nature have existed and been well-known for an extensive period of time, however, they still remain up-to-date and without a definite resolution. Over the years, many authors have explored both concepts, examining various aspects of them and making appropriate suggestions. However, the series of new and increasingly debatable issues is endless. This determines their significance both theoretically and practically thus researching them will always be of interest and can never be considered as fully completed. The purpose of this paper is to examine two debatable and current aspects of the PE and FE concept – tax treatment of the subsidiary and digital economy. These two issues are both different and similar and continue to raise follow-up discussions and the lack of definitive answers.



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