Global trading

OECD Discussion Draft part III (Enterprises carrying on global trading of financial instruments) deals with the allocation of profits to permanent establishments of global trading companies. This article focuses on the tax treatment of global trading companies in the Netherlands. The author clarifies what type of activities a global trading company may perform, as well as how the functions and responsibilities of a head office and permanent establishments can vary from one company to the next. Models are used to illustrate the various business structures used by firms enganged in global trading. The Dutch experience of application of the description in Discussion Draft part III is covered, as well as functional analysis and benchmarking. Finally, the transfer pricing methods used in practice are discussed.