Attributing Profits to Permanent Establishments: Lessons from the Swedish Supreme Administrative Court on the Influence of OECD Guidance
New
Journal
Sweden
International Transfer Pricing Journal 2026 (Volume 33), No. 2
In this article, the author examines a recent judgment of the Supreme Administrative Court of Sweden concerning the attribution of profits to a permanent establishment. The case specifically addressed the relationship between OECD guidance and traditional domestic legal sources, highlighting the growing influence of soft law in the field of international taxation.