Recent developments regarding deductibility of interest on loans provided by a general enterprise to its permanent establishment

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

Deals with the OECD Discussion Draft regarding the allocation of profits to permanent establishments. The OECD Draft is further discussed, as well as (its meaning for) the tax treatment in the Netherlands of interest payments on loans provided by a general enterprise to its permanent establishment in the Netherlands.