Permanent establishment profit allocation clarified: include sales of similar goods and disallow internal deductions between PE and head office. Article 7 treats PE profits as including profits from sales of the same or similar goods sold through the PE and disallows deductions for payments (other than reimbursement of actual expenses) between the PE and head office or other offices by way of royalties, fees, commissions, management charges, or, except for banking enterprises, interest; reciprocal charges by the PE to the head office are likewise disregarded.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Permanent establishment profit allocation clarified: include sales of similar goods and disallow internal deductions between PE and head office.
Article 7 treats PE profits as including profits from sales of the same or similar goods sold through the PE and disallows deductions for payments (other than reimbursement of actual expenses) between the PE and head office or other offices by way of royalties, fees, commissions, management charges, or, except for banking enterprises, interest; reciprocal charges by the PE to the head office are likewise disregarded.
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