Recent developments regarding allocation of profit to permanent establishments of banks

Journal
Bakker, A.J.; Hoey Smith, A. van
International Transfer Pricing Journal 2004 (Volume 11), No. 1
PriceUSD 45

Looks into the more specific issue of the allocation of profits to permanent establishments of banks. The working hypothesis as described in the OECD Discussion Draft - and its various steps - is explained, and attention is paid to the treatment of internal interest. In the case of banks, important considerations are for example minimum capital requirements and the credit rating of the bank.