Attribution of profit to a permanent establishment of a bank

Journal
Bakker, A.J.
International Transfer Pricing Journal 2005 (Volume 12), No. 2
PriceUSD 45

Case note on a Netherlands recent Appeal Court case on the attribution of equity to a Netherlands branch of a Belgian resident bank. The case is described in detail and the relevant issues (such as the possible relevance of the Second Banking Directive) are analysed in a clear way. The author concludes with a comparison between this case and the recent work of the OECD in this field.