In July 2008, the OECD published the final version of a three-part report on the attribution of profits to permanent establishments. In this article from Tax Planning International Transfer Pricing, NERA Special Consultant Pim Fris, Director Dr. Emmanuel Llinares, and Vice President Sébastien Gonnet examine Part I of the OECD report, “General Considerations.” This part of the report creates a new consistency in approaches to profit attribution between operational units inside multinational enterprises, sharpens the definition of the “functionally separate entity” approach, and introduces a new idea in transfer pricing, the concept of “significant people functions.”