International - Using the Capital Allocation Approach to Attribute Capital to a Permanent Establishment
- T. Schwärzler
- International Transfer Pricing Journal, 2017 (Volume 24), No 2
- 22 March 2017
The author considers the capital allocation approach, emphasizing that the attribution of capital is a pivotal step in the process of allocating profits to a permanent establishment. Attributing capital to a permanent establishment is not only a prerequisite for the full implementation of the authorized OECD approach, but could also have an influence on avoiding or minimizing double taxation or less than single taxation.