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 ... Summary
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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