अंतर्राष्ट्रीय कर संधियों के तहत निम्नलिखित में से कौन एक निश्चित स्थायी प्रतिष्ठान (Fixed Permanent Establishment - PE) का गठन करता है?

With reference to the OECD-G20 Base Erosion and Profit Shifting (BEPS) framework, consider the following statements: I. BEPS strategies enable multinational enterprises to legally exploit mismatches in international tax rules to shift profits to jurisdictions with little or no economic substance. II. The fiscal impact of BEPS is relatively higher on developing countries because they rely more heavily on corporate income tax as a share of total tax revenue. III. The introduction of the Global Minimum Corporate Tax under Pillar Two has completely neutralized all forms of BEPS-related tax avoidance. How many of the above statements are correct?

With reference to the OECD-G20 Base Erosion and Profit Shifting (BEPS) framework, consider the following statements: I. BEPS strategies enable multinational enterprises to legally exploit mismatches in international tax rules to shift profits to jurisdictions with little or no economic substance. II. The fiscal impact of BEPS is relatively higher on developing countries because they rely more heavily on corporate income tax as a share of total tax revenue. III. The introduction of the Global Minimum Corporate Tax under Pillar Two has completely neutralised all forms of BEPS-related tax avoidance. How many of the above statements are correct?