Recent developments in the global business environment which are characterized by intense competition and rapid growth of multinational enterprises have led to new business models and structuring of business operations in order to meet the increasing demands of expansion on a global scale.

Agency arrangements, as a way for enterprises to have sales presence in local markets, have been widely-recognized as a business strategy to attain commercial efficiencies in undertaking cross-border trade and investment. The tax consequencesof business models and structures involving sales agents across different jurisdictions have been the subject of attention and major concern in international taxation as it relates to problems on a aggressive tax planning and base erosion and profit shifting (BEPS).

Treaty issues on permanent establishments