International - Transfer Pricing, Users’ Participation and Profit Attribution to Digital Permanent Establishments: A Case Study
- R. Petruzzi
- International Transfer Pricing Journal, 2019 (Volume 26), No 2
- 11 February 2019
The recent introduction into the tax legislations of some countries of the definitions of “digital” permanent establishments (PEs) will necessarily generate the issue of assessing how much profit to attribute to a digital PE. This significant issue is still open to discussion and interpretation. This article aims at illustrating the issue by means of a practical example, as well as by providing some preliminary solutions to the issue.