Details

  • Service: Tax, Global Transfer Pricing Services (GTPS)
  • Type: Business and industry issue
  • Date: 4/1/2010

The OECD Report on the Attribution of Profits to Permanent Establishments 

The Report on the Attribution of Profits to Permanent Establishments describes how profits should be attributed to permanent establishments in accordance with the OECD Model Tax Convention's tax treaty provisions. It contains sections devoted to special considerations for banks, global trading of financial instruments, and insurance companies, and acts as a key source of transfer pricing guidance for the financial services industry, both in the context of branches, and in practice, also subsidiaries. The Chinese language edition of the Report produced by KPMG under authorisation by the OECD, features English text and Chinese translation side by side, and includes insightful forewords by Mary Bennett, Head of the Tax Treaty, Transfer Pricing & Financial Transaction Division of the Centre for Tax Policy & Administration at the OECD, and Liao Ti Zhong, Deputy Director of the International Division at China's State Administration of Taxation.

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