Taxed Out: How and why data centres are becoming a global tax flashpoint episode artwork

EPISODE · Feb 23, 2026 · 11 MIN

Taxed Out: How and why data centres are becoming a global tax flashpoint

from Ashurst Legal Outlook Podcast · host Ashurst Perkins Coie

In this episode of Taxed Out, Vanja Podinic and Colin Little explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment (PE), transfer pricing, intangible licensing and anti-avoidance, and how digitalised business models challenge traditional concepts like “fixed place of business”. The conversation highlights the pressure points and divergent international approaches and practical takeaways. To hear future episodes of Taxed Out, subscribe via your preferred podcast platform or visit ashurst.com/podcasts. The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Listeners should take legal advice before applying it to specific issues or transactions.See omnystudio.com/listener for privacy information.

Data centres sit at the intersection of permanent establishment risk, transfer pricing, DEMPE, intangibles and withholding tax.

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Taxed Out: How and why data centres are becoming a global tax flashpoint

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This episode is 11 minutes long.

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This episode was published on February 23, 2026.

What is this episode about?

In this episode of Taxed Out, Vanja Podinic and Colin Little explore why data centre arrangements are attracting intensive and coordinated scrutiny across jurisdictions. They discuss the rise of whole-of-code reviews blending permenant establishment...

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