New Profit Attribution Rules for Construction and Exploration Permanent Establishments

Journal
Ham, S. van der; Fiehler, K.; Retzer, D.; Otte, F.
Germany
International Transfer Pricing Journal 2015 (Volume 22), No. 6
PriceUSD 45

The authors consider an ordinance that contains detailed profit attribution rules for permanent establishments and industry-specific rules. In that respect, they focus on construction and exploration sectors and outline possible consequences for taxpayers operating in these industries.