OECD says transfer pricing guidelines should be applied to permanent establishments

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

OECD says transfer pricing guidelines should be applied to permanent establishments

July 23 2008

The OECD’s transfer pricing guidelines for application to separate but associated enterprises should apply in the attribution of profits to permanent establishments (PEs), said a report by the organisation

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

NewsTransfer Pricing
more across site & shared bottom lb ros

More from across our site

Transfer Pricing
Morgan Lewis
Morgan Lewis lures Baker McKenzie’s Americas tax leader in Washington DC
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
Sam Sholli, February 12 2026
Transfer Pricing
OECD
‘Aspirational’ MAP manual should be ‘go-to’ for taxpayers: OECD expert
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
Sam Sholli, February 11 2026
Direct Tax
India Mauritius
Tiger Global analysis part 2: GAAR, JAAR and treaty benefits
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
Sanjay Sanghvi, February 11 2026
Direct Tax
Internal Revenue Serice Sign
IRS expands Tax Pro Account digital tool
The expansion introduces ‘business-level digital capabilities’ for tax professionals, the US tax agency said
Sam Sholli, February 10 2026
Direct Tax
Financial research,government taxes and calculation tax return c
The foundations of successful tax transformation
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
Russell Gammon, February 09 2026
Direct Tax
Piranha Photography - Corporate Photographer London
‘Our growth is fantastic’: Ryan leader on firm’s appeal amid expansion
Partners want to join Ryan because it’s a disruptor firm, truly global and less bureaucratic, Tom Shave told ITR
Sam Sholli, February 09 2026
Direct Tax
mark carney.jpg
A taxing week: Carney’s Davos speech could inspire a challenge to US tax dominance
If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate
Sam Sholli, February 06 2026
Direct Tax
Fair Tax Mark
This week in tax: Triodos Bank achieves Fair Tax Mark in industry first
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
Sam Sholli, February 06 2026
Direct Tax
Businessman putting a card with text code of ethics in the pocket
‘Spending time in a gentleman’s club’: CLG sacks CEO
Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations
Sam Sholli, February 05 2026
Direct Tax
Close up shake hands, Considering buying a home, investing in real estate. Broker signs a sales agreement. agent, lease agreement, successful deal.
Ryan continues acquisition drive with Scottish property tax firm buyout
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
Tom Baker, February 05 2026
Gift this article