Attribution of Functions and Profits to a Dependent Agent PE: Different Arm’s Length Principles under Articles 7(2) and 9?
- K. Dziurdź
- World Tax Journal, 2014 (Volume 6), No 2
- 1 July 2014
This article argues that under the OECD Model, conceptually, there should be no difference between the arm’s length principles of articles 7(2) and 9, and analyses how control functions as significant people functions can still lead to a net profit attribution to a dependent agent PE above zero.