2010 Branch Capital Attribution Tax Survey

2010 Branch Capital Attribution Tax Survey

In view of the 2008 OECD Report, 'Report on the Attribution of Profits to Permanent Establishments' (PE) where the OECD's Committee on Fiscal Affairs provided extensive guidance on how the profits should be attributed to a PE under tax treaties following Article 7 of the Model Convention, KPMG's Global Financial Services Tax Practice decided to update our previous survey of branch capital attribution produced in 2005.

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