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

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
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article

Attributing Profits to Permanent Establishments: Lessons from the Swedish Supreme Administrative Court on the Influence of OECD Guidance

Johan Hagelin
International Transfer Pricing Journal
Taxation and Legal Issues
article

Attributing Profits to Permanent Establishments: Lessons from the Swedish Supreme Administrative Court on the Influence of OECD Guidance

Johan Hagelin
article en

Abstract

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.

International Transfer Pricing JournalVol. 33(2)
Openalex Percentile: Top 53%
Taxation and Legal Issues
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Attributing Profits to Permanent Establishments: Lessons from the Swedish Supreme Administrative Court on the Influence of OECD Guidance — Johan Hagelin · International Transfer Pricing Journal (2026) | TGRS Research Map | TGRS