Attributing Profits to Permanent Establishments: Lessons from the Swedish Supreme Administrative Court on the Influence of OECD Guidance
In this article, the author examines a recent judgment of the Supreme Administrative Court of Sweden concerning the attribution of profits to a permanent establishment. The case specifically addressed the relationship between OECD guidance and traditional domestic legal sources, highlighting the growing influence of soft law in the field of international taxation.
Authors
- Johan Hagelin
Publication Details
- Journal
- International Transfer Pricing Journal
- Published
- 2026-02-18
- DOI
- https://doi.org/10.59403/20a207y
- Primary Topic
- Taxation and Legal Issues
- Type
- article
- Field-Weighted Citation Impact
- 0.00