000			01700nab a2200229 c 4500
999			_c145352 _d145352
003			ES-MaIEF
005			20220209130240.0
007			ta
008			220209t2021 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_967929 _aSchwarz, Magdalena
245		0	_aCan the switch-over rule and the role of permanent establishments be considered the neglected stepchildren of the GloBE proposal? _c Magdalena Schwarz
260			_c2021
500			_aResumen.
520			_aAs has already been learned as children from the fairy tales of grandparents, neglecting a child or, as is usually the case in these stories, a stepchild, will have long-term negative consequences. However, in the author’s opinion, this seems to be, at least to some extent, what the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) has been doing thus far with the role of the switch-over rule (SOR) and permanent establishments in general under Pillar Two of the OECD. This can be seen particularly by the fact that, so far, only minimal information was provided on the concrete design and role of the SOR especially compared to the other three instruments under Pillar Two. The following contribution therefore aims at a more comprehensive examination of the SOR for GloBE purposes and how (low-taxed) permanent establishments are generally dealt with under the GloBE proposal.
650			_aESTABLECIMIENTO PERMANENTE _942622
650			_aIMPUESTOS _947460
650		4	_aSEGUNDO PILAR (OCDE) _967772
650		4	_aTIPO MÍNIMO GLOBAL _967681
773	0		_9166491 _oOP 2141/2021/12 _tIntertax _w(IEF)55619 _x 0165-2826 _gv. 49, n. 12, December 2021, p. 986–994
942			_cART