The Permanent Establishment Risks for Stablecoin Issuers

Journal
Author
Rossi, G. (Giacomo)
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2026 (Volume 80), No. 7
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The stablecoin market has become a core part of the digital-asset economy, surpassing USD 280 billion and rapidly growing. This expansion raises systemic importance and cross-border tax complexity. The article analyses permanent establishment risks for issuers, focusing on infrastructure, management, personnel, reserves and evolving regulations shaping the tax nexus.