United Kingdom - Permanent Establishment Profit Attribution: United Kingdom Courts Examine the ”Authorised OECD Approach”
- International,OECD,United Kingdom
- J. Schwarz
- Bulletin for International Taxation, 2019 (Volume 73), No 6/7
- 30 April 2019
The author, in this article, considers the implications of the functionally separate enterprise concept under the Authorised OECD Approach to the attribution of profits to permanent establishments with reference to tax treaties as analysed in two UK tax cases, Irish Bank Resolution (2017) and Bloomberg Inc (2018).