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PEs & the OECD

In the first of two articles Richard Fletcher and Geoffrey Kay Baker & McKenzie LLP consider the OECD Report on the Attribution of Profits to Permanent Establishments
In December 2006 the OECD released its final version of Parts 1 to 3 of its Report on the Attribution of Profits to Permanent Establishments.1 This Report formalises more than nine years of occasionally controversial work by the OECD in relation to its interpretation of Article 7 of its Model Tax Convention on Income and Capital in light of the transfer pricing guidelines developed by the OECD in 1995.
The OECD's principal aims are to (i) to develop a methodology of attributing profits to a permanent establishment (PE) so as to minimise the incidence of double taxation and (ii) achieve a degree of...

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