OECD releases additional guidance on PE profits attribution

Mar 22,2018

OECD releases additional guidance on the attribution of profits to a PE under BEPS Action 7, considering the stakeholders’ comments received on the discussion drafts issued in 2016 and 2017; The additional guidance sets out high-level general principles for the attribution of profits to PEs arising under Article 5(5), and includes examples of a commissionaire structure for the sale of goods, an online advertising sales structure, and a procurement structure; Report...


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