OECD Guidance on the attribution of profits to permanent establishments 2008

On 17 July 2008, the OECD Council approved the release the Report on the Attribution of Profits to Permanent Establishments. The Report includes a preface and four Parts.

  • Part I sets out general considerations for attributing profits to permanent establishments, regardless of the business sector in which they operate.
  • Part II describes the application of the approach to enterprises carrying on a banking business through a permanent establishment.
  • Part III addresses the situation of permanent establishments of enterprises carrying on global trading in financial instruments.
  • Part IV deals with the application of the approach to PE of enterprises carrying on insurance activities.