Comments on profit splits, profits attributed to permanent establishments

Profit splits, permanent establishments

The Organisation for Economic Cooperation and Development (OECD) in July 2016 released two discussion drafts for comments concerning the following areas under the base erosion and profit shifting (BEPS) project:

Related content

  • A discussion draft concerning the use of “profit splits” in the context of global value chains as follow-up work in relation to BEPS Actions 8-10 
  • A discussion draft concerning the attribution of profits to permanent establishments under work in relation to BEPS Action 7

Read KPMG’s comments responding to the OECD’s request for input on the two discussion drafts under BEPS Actions 8-10: Revised Guidance on Profit Splits and the BEPS Action 7: Additional Guidance on the Attribution of Profits to Permanent Establishments

  • KPMG’s comments [PDF 84 KB] concerning the discussion draft under BEPS Actions 8-10
  • KPMG’s comments [PDF 66 KB] concerning the discussion draft under BEPS Action 7

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