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October 2, 2025Deleted Journal2 citations

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

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SAStéphane AustryRVRichard J. VannJJJohn F. Jones

Key Points

  • The article finds significant practical impacts of the AOA on banks’ free capital, affecting their operational strategies.
  • Evidence suggests that there's an asymmetry between the AOA and transfer pricing rules that may complicate compliance.
  • The exploration includes a comparison across jurisdictions, revealing varied reception and implementation of the AOA.
  • Future developments may refine profit attribution methods, indicating an evolving landscape in international taxation.

Abstract

Part One of this article reviewed the purpose and history of permanent establishment (PE) taxation and examined the uneven reception of the Authorised OECD Approach (AOA) across major jurisdictions. Part Two explores the AOA’s practical impact, focusing on banks’ free capital, and addresses concerns about its asymmetry with transfer pricing rules. The article concludes with possible future developments and pathways for refining profit attribution.

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Cite This Study

Austry et al. (2025) studied this question.

synapsesocial.com/papers/68de5da283cbc991d0a20961https://doi.org/10.59403/33y50ds
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