The Authorized OECD Approach on the Attribution of Profits to Permanent Establishments: Recent Developments in Transfer Pricing
Madrid, Spain
2 October 2008
Hosted By: NERA Economic Consulting
On 17 July 2008, the OECD Council approved the release of the final version of the Report on the Attribution of Profits to Permanent Establishments. The Report provides guidance on the principles for attributing profits to a permanent establishment under Article 7 of the OECD Model Tax Convention on Income and Capital. It reflects the results of work undertaken to examine how the principles developed in the OECD's Transfer Pricing Guidelines for application to separate but associated enterprises should apply in the context of the relationship between a permanent establishment and the rest of the enterprise to which it belongs. This lunch seminar created a forum for discussion, allowing clients and colleagues to exchange views on new developments in transfer pricing.
To discuss this new approach, NERA hosted a lunch seminar on 2 October in our Madrid office. Special Consultant Pim Fris and Vice President Sébastien Gonnet reviewed the principles of the approach, focusing on the following topics:
Please email NERAMadridTP@nera.com to register for this free event.
To contact us about this event, please click here.
