Digital Permanent Establishment (Updated Blueprints)

The Multilateral Convention to Implement Amount A of Pillar One will very likely not be ratified by a sufficient amount of countries. The goal of Peter Hongler’s paper is to outline how the UN could approach the topic of a digital presence test as one option for the First Protocol under the UN Framework Convention. Such a move back to square one is of course for the involved people highly frustrating as a lot of work has been invested, however, on the other hand it also creates chances to approach the topic in a different form and based on a different rationale.