Revision of “Permanent Establishment” in the Context of Digital Economy: The Work of the OECD and Some Implications for Vietnam

The exponential growth of the digital economy has brought unprecedented challenges to the global tax system, necessitating a revision of the concept of “permanent establishment” to align with the evolving business landscape. In this paper, the authors analyze the efforts of the Organization for Economic Cooperation and Development (OECD) in tackling these challenges, primarily through the Inclusive Framework on Base Erosion and Profit Shifting. Additionally, the authors delve into Vietnam’s proactive involvement in the OECD’s initiative and its implications for tax system reform in Vietnam. Based on these analytical findings, we offer practical solutions for Vietnam to modernize its tax system and protect its taxing rights in an ever-changing world.