The rules regulating the attribution of profit to permanent establishments (PEs) are a fundamental feature of the existing international tax system yet are bese

Attribution of Profits to Permanent Establishments: Issues and Developments The profit attribution to permanent establishments is one of the most controversial

The Indian government has recently released a discussion draft report on Attribution of Profits to PE. The report is of significant importance and represents an

The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods,

This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and