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BEPS discussion drafts on PEs and profit splits

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The OECD invites comments by 15 September 2017 on two BEPS discussion drafts, one dealing with the attribution of profits to permanent establishments (PEs) under BEPS Action 7, the other containing revised guidance on profit splits in relation to BEPS Action 10.

  • Additional guidance on attribution of profits to PEs (Action 7): this discussion draft replaces the July 2016 draft, setting out high level general principles for the attribution of profits to PEs, confirming the principle that PEs are treated as separate entities for the purpose.
  • Revised guidance on profit splits (Action 10): this discussion draft builds on the July 2016 draft and is intended to clarify the application of the transactional profit split method, providing additional guidance on determining the profits to be split, although it does not, at this stage, reflect a consensus position of the governments involved.


Issue: 1360
Categories: News , International taxes