The Attribution Of: Profits To Permanent Establi...

While the AOA is the standard, some countries (including many that follow the UN Model Tax Convention ) use different methods:

: Dealing between the head office and the PE must reflect market prices (arm's length) as if they were independent parties. 2. The Authorized OECD Approach (AOA) The Attribution of Profits to Permanent Establi...

: Profit attribution is limited to the actual profits earned by the MNC as a whole from the activity the PE participated in. While the AOA is the standard, some countries