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The attribution of profits to permanent establishments paper

Published on 19 Feb 14 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • principles for attributing profits to PEs (excluding Subdivisions 815-B and 815-C)
  • practical issues in PE profit attribution
  • effect of Subdivisions 815-B and 815-C of ITAA 1997
  • effect of adopting the AOA
  • adoption of the AOA by other countries.

Author profile:

Ian Fullerton CTA
Ian is a Consultant in the Tax group of Ashurst in Sydney. He joined the firm in 2012 after 14 years in group tax and institutional banking roles at two major Australian banks. At Ashurst, Ian advises on the tax aspects of a range of banking and corporate activities and has been involved with industry submissions on various cross-border tax issues, including the operation of the new transfer pricing rules. He is an author of the Thomson Reuters Australian Tax Handbook with responsibility for chapters on debt and equity, financial transactions, asset financing, trusts and tax planning and he is the author of the Tax chapter in Ford & Lee: The Law of Trusts. Current at 15 October 2014 Click here to expand/collapse more articles by Ian FULLERTON.
 

This was presented at 2014 Financial Services Taxation Conference.

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