This content is from: Transfer Pricing

OECD approach to PEs: When arm’s length agent compensation is enough

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.

To access our market-driven intelligence please request a trial here.

Read this article – and more – for a 30 day period.

REQUEST ACCESS

Are you already an ITR subscriber? Log in here

Instant access to all of our content. Membership Options | 30 Day Trial

Related