Permanent Establishment in the Digital Age: Improving and Stimulating Debate Through an Access to Markets Proxy Approach

I. The History of Permanent Establishment as a Means of Assigning Taxing Jurisdiction

II. Current Arguments For and Against the Viability of the Current Use and Conception of Permanent Establishment

A. Arguments For Changing the Current Permanent Establishment Rules
B. Arguments for Maintaining the Current PE System

III. Permanent Establishment as an Access to Markets Proxy