What 2010 Report on the Attribution of Profits to Permanent Establishments requires
This report establishes the Authorised OECD Approach (AOA) for attributing profits to a permanent establishment (PE) for corporate income tax purposes, as endorsed by the OECD Council. The AOA requires treating the PE as a functionally separate entity and applying the arm's length principle to its internal dealings with other parts of the enterprise, based on a two-step analysis under Article 7 of the OECD Model Tax Convention.
Pillar: Tax & Transfer Pricing · Authority: Organisation for Economic Co-operation and Development (OECD) · Version: 1.0.0 · Last updated:
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Primary Citations — 7 traced to source
- 2010 Report on the Attribution of Profits to Permanent Establishments, Part I: General Considerations, Section B(i), Paragraph 15 (The functionally separate entity approach)
- 2010 Report on the Attribution of Profits to Permanent Establishments, Part I: General Considerations, Section D.2 (Step one: determining the activities and conditions of the hypothesised separate enterprise)
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