Attribution of Profits to Permanent Establishments: Should the AOA Be Maintained as the OECD Standard?

Globalization has led to enterprises doing cross-border business operating through foreign permanent establishments. However, the allocation of profits to such permanent establishments has always been problematic. This article analyses the authorized OECD approach as compared with the previous method of calculating the profit attributions to permanent establishments and thereby addresses the question of whether the authorized OECD approach should be maintained as an OECD standard.