In the second of two articles Richard Fletcher and Geoffrey Kay Baker & McKenzie LLP consider the OECD Report on the Attribution of Profits to Permanent Establishments
In December 2006 the OECD released the final versions of parts 1 to 3 of its Report on the attribution of profits to a permanent establishment (PE). In the first part of this article we reviewed the key aspects of the newly authorised OECD methodology for attributing profits to a PE. In this part we examine key concerns with the Report and review the uncertainties still inherent in the process.
Key Issues And Concepts
Although the key principle of a PE being considered as...
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In the second of two articles Richard Fletcher and Geoffrey Kay Baker & McKenzie LLP consider the OECD Report on the Attribution of Profits to Permanent Establishments
In December 2006 the OECD released the final versions of parts 1 to 3 of its Report on the attribution of profits to a permanent establishment (PE). In the first part of this article we reviewed the key aspects of the newly authorised OECD methodology for attributing profits to a PE. In this part we examine key concerns with the Report and review the uncertainties still inherent in the process.
Key Issues And Concepts
Although the key principle of a PE being considered as...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")