Insights
Tax Intelligence, Decoded
Analysis, commentary, and updates from the intersection of AI and international tax.
PE Analysis
Remote Work and PE Thresholds: What Changed in 2026
February 8, 2026
New OECD guidance reshapes how remote workers create permanent establishment risk. A practical analysis of the updated Commentary.
Pillar 2
Pillar 2 Safe Harbours: Transitional Rules Expiring Soon
February 5, 2026
The CbCR-based transitional safe harbour ends in 2028. What MNE groups need to prepare for the full GloBE calculations.
Treaty Law
Treaty Shopping After the MLI: Where Do We Stand?
January 28, 2026
With the MLI now in force for most major treaty networks, we examine the practical impact of the Principal Purpose Test on holding structures.
More articles coming soon.