Guidance on the attribution of profits to permanent establishments 2008

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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.