Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7
收藏Organisation for Economic Co-operation and Development2026-02-07 收录
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https://www.oecd.org/en/publications/additional-guidance-on-the-attribution-of-profits-to-a-permanent-establishment-under-beps-action-7_b4251c9d-en.html
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This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes in the Report on BEPS Action 7 to Article 5 of the OECD Model Tax Convention. This additional guidance sets out high-level general principles for the attribution of profits to permanent establishments arising under Article...
