This presentation covers:
- principles for PE profit attribution
- practical issues in PE profit attribution
- effect of Subdivisions 815-B and 815-C
- effect of adopting the AOA
- adoption of the AOA by other countries.
maintenance
Finance
Investment
The attribution of profits to permanent establishments
Source: New South Wales
Published Date: 19 Feb 2014
Individual Session
The attribution of profits to permanent establishments
Author(s):
Ian Fullerton
Materials from this
session:
Details
- Published By: Ian Fullerton
- Published On:19 Feb 2014
- Took place at:InterContinental Sanctuary Cove Resort, Gold Coast
The material is copyright. Apart any fair dealing for the purpose of private study,
research critisism or review, as permitted under the copyright Act, no part may be rerpoduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
This material is copyright. Apart from any fair dealing for the purpose of private study., research, critisism or review, as permitted under teh copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opininons are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
Tags
Finance
Investment
TOFA
Transfer pricing
2014
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