11th November 2025

OECD pushes for tax rulings on Permanent Establishments: new certainty or fresh challenges for EoR models?

Global employers are facing new scrutiny over how tax authorities view Employer of

Record (EoR) arrangements and their potential to create Permanent Establishments.

Against this backdrop, the OECD’s move to develop a ‘rulings’ system for determining

corporate tax nexus could reshape how multinational groups manage their cross-border

risks. In this piece, Vistra’s Tom Lickess and Florence Meigh explore what this means

for global employers and whether greater certainty or new challenges lie ahead.