Il tramonto del binomio “residenza-stabile organizzazione” come criterio di collegamento territoriale per i redditi delle imprese multinazionali

The article deals with the issue of the nexus principle for business income taxation, with particular regard to MNEs. Having made a historical examination of the genesis of the current residence and permanent establishment criteria, the article denounces their inability to meet the needs posed by the globalised and digitalised economy of current times. It is then proposed to identifiy a genuine link for corporate income taxation connected to the market jurisdictions where business is carried out, according to a destination-based approach, with some possible adjustments. In light of this, the proposals developed at European and global level are critically examined, with particular reference to the Global Minimum Tax.