Permanent establishment, Is the seat of management a new criterion for the domicile of legal persons?

Abstract

In this article, the author reflects on the incorporation of the criterion of "effective management headquarters" as a new criterion to determine the fiscal domicile of legal persons. What is an address? Is it possible that, through the regulation of the permanent establishment figure, a new criterion has been created to determine the domicile of legal entities in a manner similar to the effective management headquarters? This are some of the questions to which the author will respond, within the framework of the enactment of Legislative Decree No 1424.