Report on the attribution of profits to permanent establishments : 22 July 2010 | Rapport sur l'attribution de bénéfices aux établissements stables : 22 juillet 2010

Resource Information

The work Report on the attribution of profits to permanent establishments : 22 July 2010 | Rapport sur l'attribution de bénéfices aux établissements stables : 22 juillet 2010 represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Report on the attribution of profits to permanent establishments : 22 July 2010 | Rapport sur l'attribution de bénéfices aux établissements stables : 22 juillet 2010

Creator

• OECD Centre for Tax Policy and Administration

Subject

• PE
• allocation of profits
• banking
• financial instrument
• global trading

Language

eng

Summary

This final report, which includes Parts I-IV, provides the views of the Committee as to how the profits attributable to a permanent establishment should be determined. This report does not change the conclusions of the 2008 Report and has been prepared simply to avoid difficulties that might arise in trying to use the 2008 Report for the interpretation of the new Article 7. This final version stresses that this report is not intended to affect in any way the currently existing standards under Article 5 for determining the existence of a PE. Finally, this Report has been based upon the principle of applying by analogy the guidance found in the Guidelines for purposes of determining the profits attributable to a PE. To the extent the guidelines are modified in the future, this report should be applied by taking into account the guidance in the guidelines as so modified from time to time

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction