The Resource Attribution of profits to permanent establishments - part 1

Attribution of profits to permanent establishments - part 1

Label
Attribution of profits to permanent establishments - part 1
Title
Attribution of profits to permanent establishments - part 1
Subject
Language
eng
Summary
QUESTIONS: I. Issue One: Do the Revenue Authorities of your country agree with the Authorised OECD Approach for profit attribution to permanent establishments (PEs) or do they attribute profits to PEs on some global formulary or profit split approach, regardless of the functional, asset and risk profiles of the PEs? II. Issue Two: Do the Revenue Authorities of your country treat a subsidiary of a foreign company, operating as a captive service provider, say providing services of contract software development; back office; contract or toll manufacturing, etc., on a cost plus basis, as "fixed place of business PE" of the foreign company, solely on the ground that the premises of such subsidiary is at the disposal of the foreign company? III. Issue Three: If the answer to Issue Two is in the affirmative, how would the Revenue Authorities of your country attribute profits to such PE under any one or both of the following situations: a. None of the employees of the foreign company were present in your country for any considerable period of time; b. Some of the employees of the foreign company were present in your country for a considerable period of time? IV. Issue Four: Do the Revenue Authorities of your country take into account the concept of "significant people functions" in the context of "dependent agency PEs", for the purposes of attributing profits to such PEs in excess of the remunerations received by the local agents, which create such "dependent agency PEs"? V. Issue Five: Do the Revenue Authorities of your country accept the method of "Berry Ratio" for the purposes of attributing profits to "dependent agency PEs", in situations where imputed remuneration based on value of goods, say return on sales, produce extremely high results of return on operating costs, primarily due to significantly high value of goods, as compared to low levels of operating costs?
Citation source
In: Transfer pricing forum. - Arlington. - Vol. 2 (2011), no. 2 (May) ; 75 p
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • allocation of profits
  • PE
  • AOA
  • global formulary apportionment method
  • profit split method
  • fixed place of business
  • foreign company
  • significant people functions
  • agency PE
  • Berry ratio
Label
Attribution of profits to permanent establishments - part 1
Instantiates
Publication
Label
Attribution of profits to permanent establishments - part 1
Publication

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