The international approach to corporate income taxation (hereafter CIT) has historically been based on the concept of Permanent Establishment (hereafter PE). Jurisdictions implemented their local tax rules (buttressed by domestic legislation) on multinational enterprises (hereafter MNEs) with PE. This was straightforward for the extractives sector since MNEs could not operate in a country without a PE. Nevertheless, it raised issues of allocating taxing rights over the profits of MNEs operating in more than one country since jurisdictional differences may result in the profits of MNEs being taxed more than once across different jurisdictions, resulting in double-taxation. Jurisdictions competing for taxing rights can therefore distinguish between “source countries”, “intermediate countries” and “residence countries”.