This content is from: Direct Tax
Attributing profits to a PE: a US perspective
Determining the profits attributable to a PE is poorly explicated in practice. The OECD has drafted a proposal to clarify matters. By Philip R West, Andersen Office of Federal Tax Services, Washington, DC, and Robert Janukowicz and W Anne Jie, Andersen, New York
To access our market-driven intelligence please request a trial here.
Read this article – and more – for a one-week period.
REQUEST ACCESSAre you already an ITR subscriber? Log in here