The article examines profit attribution in international taxation through a court case, highlighting OECD guidance implications.
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.
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Johan Hagelin (2026) studied this question.
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