Business Services Industry
Attribution of profits to a permanent establishment in the United Kingdom.
Australasian Business Intelligence, May, 2006
Byline: Gary J Mills and Shiv Mahalingham
May 09, 2006 (Tax Planning International Transfer Pricing - ABIX via COMTEX) -- The question of how to attribute profits to a permanent establishment (PE) in the UK is difficult. The attribution of profits to a PE of a non-resident company requires the application of fictional arrangements and transactions with the non-resident entity. The UK aligned its rules with the OECD's model treaty. However, the OECD has now adopted the working hypothesis that profits should be attributed on a separate entity approach basis. The profile of the hypothecated entity, in relation to assets, risks assumed and debt, should be deduced from a detailed functional and factual analysis.
Publication Date: February 2006...
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