Consultation with Business on the OECD Discussion Draft on the Attribution of Profits to Permanent Establishments (Parts I & II): Case Study C16-Apr-2002 Functional analysis, recognition of dealings, characterisation of dealings, attribution of capital to a Banking Permanent Establishment, split functions. Also available: |
Consultation with Business on the OECD Discussion Draft on the Attribution of Profits to Permanent Establishments (Parts I & II): Case Study B16-Apr-2002 Attributing Financial Assets: Importance of the Sales/Trading Function. Example Where Loan Booking Jurisdiction is not in Line with Functional Analysis Also available: |
Consultation with Business on the OECD Discussion Draft on the Attribution of Profits to Permanent Establishments (Parts I & II): Case Study A16-Apr-2002 Relating to the general situation ( Part 1): A permanent establishment is engaged in Research and Development activities leading to the development of intangible property rights. How should dealings be recognised and characterized? Related documents: |
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