Permanent Establishments Claim Their Share of Profits: Does the Taxman Agree?

Journal
Malherbe, J.; Daenen, P.
International; OECD
Bulletin for International Taxation 2010 (Volume 64), No. 7
FormatPDF
EUR
40
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45 (VAT excl.)

In this article, the authors consider the theoretical background to the attribution of profits to permanent establishments in the light of the 2008 and the (proposed) 2010 versions of Art. 7 of the OECD Model Tax Convention and whether or not tax administrations worldwide will agree with the theory.