Comparing the "Discussion draft on the attribution of profits to permanent establishments (PEs: part III (enterprises carrying on global trading of financial instruments)" with the OECD's "The taxation of global trading of financial instruments"

Compares the March 2003 OECD "Special considerations for applying the working hypothesis to permanent establishments of enterprises carrying on global trading of financial instruments" and the 1998 OECD document "The taxation of global trading of financial instruments". The article highlights the developments in the OECD's positions and the distinctions that arise from operating in a branch form as opposed to a subsidiary form.