The Effect of the OECD/G20 BEPS Initiative on the Attribution of Profits to Permanent Establishments: The Special Case of Agency Permanent Establishments

In this article, the author examines the effects of the OECD/G20 Base Erosion and Profit Shifting initiative on the attribution of profits to agency permanent establishments, focusing on the OECD’s Additional Guidance on the Attribution of Profits to Permanent Establishments, Action 7 – 2016 Public Discussion Draft.