The OECD has published revised draft guidance on the attribution of profits to permanent establishments to address certain changes to the OECD model tax treaty. The new draft includes high-level general principles for the attribution of profits to permanent establishments and a series of illustrative examples.
The OECD also has published a discussion paper on Action 10 of the BEPS project which includes revised draft guidance on the application of the transfer pricing profit split method and on the determination of the profits to be split. The revised draft also includes a number of illustrative examples.
Comments on the revised guidance are welcomed by the OECD by 15 September.