Profit Attribution To Permanent Establishments A Tax Treaty Perspective On The Single Taxpayer Approach
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Profit Attribution to Permanent Establishments : a Tax Treaty Perspective on the "single Taxpayer" Approach
| Author | : S.B. Law |
| Publisher | : |
| Total Pages | : |
| Release | : 2018 |
| Genre | : |
| ISBN | : |
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In this article, the author provides a tax treaty perspective on the OECD's Additional Guidance on the Attribution of Profits to Permanent Establishments, Action 7 - 2017 Public Discussion Draft, observing that countries which continue to follow article 7 of the pre-2010 OECD Model and the current UN Model would likely not accept the "single taxpayer" approach of attributing zero or minimal profits to a permanent establishment.
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