INTERNATIONAL: ATTRIBUTION OF PROFIT TO A PERMANENT ESTABLISHMENT OF A GLOBAL TRADING COMPANY

On 4 March 2003, the OECD published an addition to the discussion draft titled "The attribution of profits to permanent establishments". The newly added Part III, "Enterprises Carrying on Global Trading of Financial Instruments" concerns enterprises engaged in the global trading of financial instruments. This new Part III to the discussion draft, issued by the Committee on Fiscal Affairs of the OECD, deals with the allocation of profits to permanent establishments of global trading companies. This article will focus on Part III, in which the steering group on transfer pricing presents an outline on how profits should be attributed to permanent establishments of global trading companies. Parts I and II will be addressed in this context, as the working hypothesis for the preferred approach to allocating profits to permanent establishments is dealt with in Parts I and II.