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 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.
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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 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.
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:
