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