The OECD Committee on Fiscal Affairs points out that, while a location where automated equipment is operated by an enterprise “may constitute a permanent establishment in the country where it is situated”, a distinction needs to be made “between computer equipment, which may be set up at a location so as to constitute a permanent establishment under certain circumstances, and the data and software which is used by, or stored on, that equipment”
Eso fue horribleMultiUn MultiUn