Monday, October 10, 2005

The Attribution of profits to PE - saga continues

On 27 June 2005 the OECD Committee on Fiscal Affairs released for public comment a Discussion Draft on the Attribution of Profits to Permanent Establishments of Insurance Companies. The following contributions from the business community can now be downloaded from the OECD website: * American Council of Life Insurers * Association of British Insurers * BIAC * CEA * Deloitte * Ernst & Young * KPMG * Lloyd’s * PricewaterhouseCoopers * XL Capital Group of Companies * Zurich Financial Services

On the same press release, the OECD provides an update on its controversial project of developing new guidance on attributing profits to permanent establishments under Article 7 of the Model Tax Convention. As the readers are awere, the project is based: (1) working hypothesis that treats a permanent establishment as a functionally separate entity for the purposes of attributing tax profits; and (2) application by analogy to permanent establishmentst of the transfer Pricing guidelines. According to the OECD this issues are still under discussion and are expected to be finalised by January 2007. View


Blogger chocoholic said...

Smith & Hawken launches redesign of retail stores
Reflects store growth Smith & Hawken , Novato, Calif., has contracted McCall Design Group and Line Brand Architecture of San Francisco to create a new store design.
Just wanted to say hi and check out some of the comments on your blog. Some of these are pretty weird.

I seriously would like you to check out my store though. It is related to specialty chocolate gift Know I know not everyone likes specialty chocolate gift , but those people are usually hard to find.

Come by when you get a chance and look around. I think you will love it.

10 October, 2005 22:46  
Blogger Unknown said...

So many blogs and only 10 numbers to rate them. I'll have to give you a 8 because you have good content.

Free Access To More Information Aboutdevelopment finance

11 October, 2005 11:44  

Post a comment

<< Home