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Attribution of Profits to Insurance Branches

John Neighbour Partner and Jennifer Coletta Tax Manager KPMG look at the OECD discussion draft on how insurance branches (permanent establishments or PEs) should be taxed
The discussion draft published on 29 June 2005 is Part IV of a series of discussion drafts dealing with the principles of taxation for PEs. A year on are we any closer to a conclusion?
Background to Part IV
The OECD's work on PEs is effectively an extended commentary on Article 7 of its Model Tax Convention which forms the basis of many double tax treaties.
Article 7 looks at attributing profits to permanent establishments. The OECD discussion documents Parts...

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