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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With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’