Besteuerung der digitalen Wirtschaft

The study examines the taxation of the digitale economy through a case analysis of decentralized permanent establishments. It argues that traditional PE criteria—such as a fixed place of business and disposal over relevant structures—can also apply to digital settings. The analysis shows that, although personnel functions and physical elements are in fact present, they are often not taxed despite generating substantial value creation. This becomes evident in decentralized forms such as home‑office and server‑based permanent establishments, which allow these value‑creating activities to be captured appropriately.