Guidance Issued on Profit Attribution to Permanent Establishments

Journal
Dijkman, J.; Buck, S.; Brouwers, D.M.
Netherlands
International Transfer Pricing Journal 2011 (Volume 18), No. 3
FormatPDF
EUR
40
| USD
45
(VAT excl.)

On 27 January 2011 the State Secretary for Finance published a decree on the attribution of profits to permanent establishments for Dutch corporate income tax purposes. The Decree was issued in response to the OECD's "Report on the Attribution of Profits to Permanent Establishments", the 2008 revised commentary to Art. 7 of the OECD Model Tax Convention and the 2010 release of a new Art. 7 of the OECD Model (including commentary).