On July 17, the OECD issued its final report on the attribution of profits to permanent establishments, reaffirming the “separate entity approach” that hypothesises a permanent establishment (PE) as a separate and distinct enterprise that may deserve additional compensation according to the arm’s-length principle. The report notes, say Brandon Feldman and Patrick Breslin of the Ballentine Barbera Group, that the OECD transfer pricing guidelines should apply in such cases.
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Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
The future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general