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Search results with tag "Additional guidance on the attribution"
Additional Guidance on the Attribution of Profits to ...
www.oecd.orgAs to the profit attribution rules, the Report concluded that the changes to the definition of PE in Article 5 of the OECD Model Tax Convention did not require substantive modifications to the existing rules and guidance on attribution of profits to PEs under Article 7 of the OECD Model Tax Convention. However, the Report did mandate the