Profit Attribution to Permanent Establishments – A Tax Treaty Perspective on the “Single Taxpayer” Approach

In this article, the author provides a tax treaty perspective on the OECD’s Additional Guidance on the Attribution of Profits to Permanent Establishments, Action 7 – 2017 Public Discussion Draft, observing that countries which continue to follow article 7 of the pre-2010 OECD Model and the current UN Model would likely not accept the “single taxpayer” approach of attributing zero or minimal profits to a permanent establishment.