The Resource The attribution of profits to a permanent establishment : issues and recommendations

The attribution of profits to a permanent establishment : issues and recommendations

Label
The attribution of profits to a permanent establishment : issues and recommendations
Title
The attribution of profits to a permanent establishment : issues and recommendations
Creator
Subject
Language
eng
Summary
Description of the historical US treaty policy regarding the attribution of profits to a permanent establishment. An analysis is given of the purpose of profit attribution provisions in tax treaties and their implications for business and governments. In addition, the main aspects of a recent OECD report on the allocation of profits to a permanent establishment are described with particular emphasis on political and technical issues, such as a symmetrical application, a functional analysis, the attribution of assets to a PE, risk assumptions, attribution of capital, comparability, transfer pricing methods and dependent agent PE's. The last parts deal with practical implications and issues regarding US treaty provisions
Citation source
In: Intertax. - The Hague. - Vol. 33 (2005),
http://library.link/vocab/creatorName
  • Bennett, M.C
  • Dunahoo, C.A
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • PE
  • transfer pricing
  • treaty policy
  • agency PE
  • allocation of profits
Label
The attribution of profits to a permanent establishment : issues and recommendations
Instantiates
Publication
Label
The attribution of profits to a permanent establishment : issues and recommendations
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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