Profit allocation methods

Abuse of law, Abuse of rights, Anti-tax avoidance, Corporate income tax, EU law, EU/EEA, Finance, GAAR, International Tax Law, M&A and Reorganizations, MLI, MNE Profits, Permanent Establishments, Principal purpose test, Principal/ancillary arrangements, Profit allocation methods, Tax Avoidance, Transfer Pricing, United Kingdom, United States

(Temple Tax Chambers; King’s College London)/ /Leave a comment

When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain circumstances where DPT applied, was a new development? What did it mean? I was reminded of that discussion this week as a result…

Permanent Establishments, Profit allocation methods, Switzerland

(Homburger)/ /Leave a comment

Swiss Domestic Law provides for an unlimited personal tax liability for companies if their registered offices or their effective place of management is located in Switzerland. This tax liability however does not extend to permanent establishments abroad.[1] The delimitation methods of the tax liability for permanent establishments in foreign countries is based on the principles…