Currently, one of the most relevant modifications of the definition of ermanent establishment (PE) is contained in the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). In order to address the perceived defects in the definition, the OECD proposed the adoption of three main modifications: the dependent agent PE (DAPE), the excluded activities provision, and the anti-fragmentation rule. For the purposes of this analysis, the authors will focus on the changes to the definition of the DAPE, which constitutes the most relevant change to the concept of PE and they will also comment on the specific case of the so-called “zero profit PE” by means of an example.
The attribution of profits to a dependent agent permanent establishment: the controversial scenario of the zero profit allocation
Rizzo, Amedeo
;
2021
Abstract
Currently, one of the most relevant modifications of the definition of ermanent establishment (PE) is contained in the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). In order to address the perceived defects in the definition, the OECD proposed the adoption of three main modifications: the dependent agent PE (DAPE), the excluded activities provision, and the anti-fragmentation rule. For the purposes of this analysis, the authors will focus on the changes to the definition of the DAPE, which constitutes the most relevant change to the concept of PE and they will also comment on the specific case of the so-called “zero profit PE” by means of an example.File | Dimensione | Formato | |
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International - The Attribution of Profits to a Dependent Agent Permanent Establishment_ The Controversial Scenario of the Zero Profit Allocation - IBFD.pdf
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