The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part One

Part One of this two-part article reviews permanent establishment (PE) taxation by examining the development, purpose and mixed reception of the Authorised OECD Approach (AOA) across major jurisdictions, highlighting the limited consensus achieved and how the AOA has impeded further work on the attribution of profits to PEs.