%0 Journal Article
%A Escribano López, Eva Alicia
%T An opportunistic, and yet appropriate, revision of the source threshold for 21th century tax treaties
%D 2015
%@ 0165-2826
%U https://hdl.handle.net/20.500.14352/95918
%X The present paper aims to delve into one of the most thrilling debates set out by the Base Erosion and Profit Shifting (BEPS) Project (specifically Action 1): the reconsideration of the permanent establishment threshold.Without disregarding the fiscal interests that have undeniably boosted the reopening of the discussion, we prefer to question the appropriateness of the PE from a different perspective. First, we will analyse the theoretical principles that originally served to justify the PE threshold. Subsequently, we will demonstrate the obsolescence of the term - as it currently stands - as a result of the challenges posed by the so-called digital economy and in light of the aforementioned principles. Some proposals for the way forward will be briefly outlined.
%~