Talking about artificial intelligence already risks sounding outdated, given how quickly these technologies are evolving and are becoming part of everyday business practice. What only a few years ago appeared experimental or theoretical is now integrated into ordinary commercial operations. But what is happening to international tax rules? Domestic initiatives such as the digital service taxes, ongoing OECD developments, and in general different interpretative approaches adopted by tax authorities in the world are going in different directions, leaving taxpayers without a clear vision. This article examines how current rules on permanent establishment and transfer pricing, established for a “bricks and mortar" economy, can be interpreted and applied in this evolving environment.
