REPORT ON THE ATTRIBUTION OF PROFITS TO …

ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT. REPORT ON THE ATTRIBUTION OF PROFITS TO permanent ESTABLISHMENTS. PARTS I (GENERAL CONSIDERATIONS), II (BANKS) AND. III (GLOBAL TRADING). DECEMBER 2006. CENTRE FOR TAX POLICY AND ADMINISTRATION. ATTRIBUTION OF PROFITS TO permanent ESTABLISHMENTS: UPDATE ON STATUS AND RELEASE OF NEW VERSIONS OF PARTS I, II AND III. 1. As previously acknowledged by the OECD and confirmed by a recent study by the International Fiscal Association,1 the practices of OECD and non-OECD countries regarding the ATTRIBUTION of PROFITS to permanent establishments and these countries' interpretation of Article 7 (Business PROFITS ) of the OECD. Model Tax Convention vary considerably.

Commentary dealing with attribution of profits to permanent establishments with the additional guidance reflected in Parts I to III but only to the extent that such additional guidance does not conflict with the existing Commentary. It will also prepare a new version of Article 7 and its Commentary in order to fully

Tags:

  Guidance, Permanent, Profits, Additional guidance, Additional, Establishment, Attribution, Attribution of profits to permanent establishments, On the attribution of profits to

Information