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International - The Agent Permanent Establishment Reconsidered: Application of Arts. 5, 7 and 9 of the OECD Model Convention

Country:
International
Author:
F. Barreiros Rosalem
Issue:
International Transfer Pricing Journal, 2010 (Volume 17), No 1
Published:
18 December 2009
This article deals with the differences in the risk allocation proposed by the “Report on the Attribution of Profits to Permanent Establishments” and the “Transfer Pricing Aspects of Business Restructurings: Discussion Draft for Public Comment”, both by the OECD. It analyses the impact of such distinctions in the attribution of profits to dependent agent PEs and subsidiaries, respectively.
 
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