Beyond Borders: Practical Frameworks to Navigate Permanent Establishments and Profit Allocations in a Home Office Setting
Working abroad from home is a growing trend in today’s working landscape, which has not yet been reflected in the OECD Model. Therefore, this article proposes amendments to article 5 of the OECD Model to capture the establishment of home office PEs and also covers the profit allocation thereto. The recommendations made aim to find a balance between fair taxation, proportionality and simplification.
Authors
- L. Visscher
Publication Details
- Journal
- International Transfer Pricing Journal
- Published
- 2025-04-22
- DOI
- https://doi.org/10.59403/yr48xw
- Primary Topic
- Housing Market and Economics
- Type
- article
- Field-Weighted Citation Impact
- 0.00