Guidance Issued on Profit Attribution to Permanent Establishments

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).