Attribution of Profits to Agency Permanent Establishments : a Reconsideration of the Arm's Lenght [i.e. Length] Criterion?
| Author | : D.J. Jiménez-Valladolid de L'Hotellerie-Fallois |
| Publisher | : |
| Total Pages | : |
| Release | : 2016 |
| ISBN-10 | : OCLC:1262846381 |
| ISBN-13 | : |
| Rating | : 4/5 ( Downloads) |
Download or read book Attribution of Profits to Agency Permanent Establishments : a Reconsideration of the Arm's Lenght [i.e. Length] Criterion? written by D.J. Jiménez-Valladolid de L'Hotellerie-Fallois and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: According to the OECD report on the attribution of profits to permanent establishments (PEs), the attribution must be based on the so-called "authorized approach", which implies the analogous application of the OECD Transfer Pricing Guidelines to the transactions between head office and PE. However, in the case of the agency PE, the application of the Guidelines is complicated. This article proposes several alternative methods to attribute profits to agency PEs.
