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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The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes