Weakness, Uncertainty and Risk for the Petroleum Industry Related to Allocation of Income According to OECD Model Tax Treaty Articles 7 and 9
Article from: OGEL 5 (2013), in Taxation
Abstract
The intention of the OECD's 2010 Report on the Attribution of Profits to Permanent Establishment (the Attribution Report) was to establish an authorized approach for the attribution of profits, and they succeeded. The authorized approach for attribution of income and expenses is applicable to all industries, as well as for subsidiaries. However, as the report is written in very general terms, it is not particularly useful for the petroleum industry. Rather the opposite - it could create even more uncertainty, disputes, tax risks and possible tax adjustment, penalties and, ...