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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda
Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers
While AI is revolutionising tax work, it is also reshaping clients’ willingness to pay for advice and their perception of the value generated by tax advisers
The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward