Permanent Establishment Profit Attribution: United Kingdom Courts Examine the ”Authorised OECD Approach”

Schwarz, J.S.

Permanent Establishment Profit Attribution: United Kingdom Courts Examine the ”Authorised OECD Approach”

Journal

Author

Schwarz, J.S.

Country

International; OECD; United Kingdom

Published Date

30 April 2019

Issue

Bulletin for International Taxation 2019 (Volume 73), No. 6/7

DOI

https://doi.org/10.59403/2xrm2q7

Document

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The author, in this article, considers the implications of the functionally separate enterprise concept under the Authorised OECD Approach to the attribution of profits to permanent establishments with reference to tax treaties as analysed in two UK tax cases, Irish Bank Resolution (2017) and Bloomberg Inc (2018).

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Permanent Establishment Profit Attribution: United Kingdom Courts Examine the ”Authorised OECD Approach”