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Attribution of Profits to Insurance Branches

John Neighbour, Partner, and Jennifer Coletta, Tax Manager, KPMG, look at the OECD discussion draft on how insurance branches (permanent establishments, or PEs) should be taxed

 
John Neighbour Partner and Jennifer Coletta Tax Manager KPMG look at the OECD discussion draft on how insurance branches (permanent establishments or PEs) should be taxed
 
The discussion draft published on 29 June 2005 is Part IV of a series of discussion drafts dealing with the principles of taxation for PEs. A year on are we any closer to a conclusion?
Background to Part IV
 
The OECD's work on PEs is effectively an extended commentary on Article 7 of its Model Tax Convention ...

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