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PE Watch: Latest developments and trends, August 2022

11 August 2022

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Treaties, OECD, Global

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Denmark, Germany, Mauritius, Netherlands, United Kingdom

OECDBEPS MLI: Lesotho deposits instrument of ratification of the MLIOn 28 July 2022, Lesotho deposited its instrument of ratification of the Base Erosion and Profit Shifting (BEPS) Multilateral Instrument (MLI) with the Organisation for Economic Co-operation and Development (OECD). Lesotho confirmed its preliminary positions regarding the permanent establishment (PE) provisions and chose to apply all of the PE provisions of the MLI. The MLI will enter into force for Lesotho on 1 November 2022.PE tax rulingsDenmark: Sales manager does not constitute a PE in DenmarkOn 6 July 2022, the Danish Tax Board (DTB) published binding tax ruling SKM2022.357.SR. In this ruling, the...