The OECD released its first discussion draft on the attribution of profits to permanent establishments in early 2001.
Since then, quite a few updates have been released and can be found in the Library on BEPS and Transfer Pricing available here.
Additional changes were recently suggested by the OECD in the context of the Base Erosion and Profit Shifting initiative (BEPS).
It may actually be time for convergence between the application of the arm’s length principle under the OECD Transfer Pricing Guidelines and the OECD “authorized approach” for the attribution of profits to permanent establishments.
Read our latest piece on that matter titled “Attribution of Profits to Permanent Establishments: It is time for Convergence”, Tax Topics No. 2376, September 21, 2017, Wolters Kluwer, pp. 1-3.1 Reproduced with permission. Published and copyright Wolters Kluwer Canada Limited.
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