OrbitaxOrbitax

U.S. Won't Adopt BEPS Project PE Standard into Tax Treaties until Profit Attribution Sorted out

|Proposed Changes|United States
United States

According to recent comments from U.S. Treasury Attorney Advisor Brian Jenn, the U.S. will not move forward with the adoption of the new standards for permanent establishments as developed under Action 7 of the OECD BEPS Project until Treasury is confident that there is consensus with other countries on the rules for attribution of profits. The standard in question is the new anti-fragmenting r…

Continue Reading