Permanent Establishments Claim Their Share of Profits: Does the Taxman Agree?

Journal
International; OECD
Bulletin for International Taxation 2010 (Volume 64), No. 7
In this article, the authors consider the theoretical background to the attribution of profits to permanent establishments in the light of the 2008 and the (proposed) 2010 versions of Art. 7 of the OECD Model Tax Convention and whether or not tax administrations worldwide will agree with the theory.