OECD Consults on Attribution of Profits to Permanent Establishments and Revised Guidance on Profit Splits

On 22 June 2017, the OECD published public discussion drafts on:

• Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status) of the BEPS Action Plan;
• Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 (Assure that transfer pricing outcomes are in line with value creation) of the BEPS Action Plan.

Both discussion drafts build upon and replace the…