Attribution of profit to a permanent establishment of an insurance company

This article provides for an overview of the OECD Discussion Draft of the Report on the Attribution of Profits to a Permanent Establishment (Part IV (Insurance)). The author sets forth what type of activity an insurance company may perform and how the division of functions and responsibilities between head offices and permanent establishments may vary from one company to another. The step-by-step analyis of the Discussion Draft is explained. Particular attention is given to the treatment of internal interest.