Attribution of Profits to Permanent Establishments: It is time for ConvergenceBy Robert Robillard - 11 October 2017
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. Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P. Senior Partner, RBRT Fiscalité / Tax (RBRT inc.) 514-742-8086 firstname.lastname@example.org rbrt.ca The information in this blog post is general information only. Data and information come from sources believed to be reliable but accuracy cannot be guaranteed. RBRT Inc., RBRT Concepts Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. RBRT Inc., RBRT Concepts Inc. or the author are not responsible or liable with respect to the content appearing on external sources nor regarding the language of this content. The opinions expressed in this blogpost are those of the author. Readers should seek advice from RBRT Inc. as required.