OECD says transfer pricing guidelines should be applied to permanent establishments
July 24, 2008
The OECD’s transfer pricing guidelines for application to separate but associated enterprises should apply in the attribution of profits to permanent establishments (PEs), said a report by the organisation
The report, approved by the OECD Council on July 17, said the profits of a PE should be determined by applying the OECD’s transfer pricing guidelines’ arm’s-length principle, including its comparability analysis, to dealings between the PE and the rest of the enterprise to which it belongs and by pricing in accordance with the guidelines any transactions with associated enterprises attributed to the PE.
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