Permanent establishment (PE) domestic law
United States: Extension of High-Tax Exclusion rules to foreign branches and modification of the foreign branch definition
On 25 August 2021, the United States (US) Senate Finance Committee issued a discussion draft to amend certain international tax rules. Among other items, the draft proposes to extend the High-Tax Exclusion (HTE) rules to income of foreign branches. HTE rules allow taxpayers to exclude from their global intangible low-taxed income (GILT…