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24 August 2023

Thursday, 31 August 2023 | BorderCrossings with EY transfer pricing and tax professionals (1 pm ET)

Part 2: Profit attribution to permanent establishments: how do transfer pricing principles apply?

This webcast, the second in a two-part series, examines the difficulty in applying transfer pricing rules to attribute profits to permanent establishments considering both US and international tax treaties. Under US tax treaties, Article 7 governs profit attribution to permanent establishments and references the arm’s-length principle under Article 9. In response to a lack of clear and consistent interpretation of profit attribution under international tax treaties, the Organisation for Economic Co-operation and Development (OECD) developed the Authorized OECD Approach (AOA).

This webcast will discuss the following questions:

  • How has Article 7 evolved over the decades?

  • To what extent and how does the attribution of profits to permanent establishments under Article 7 apply insights from transfer pricing under the arm’s-length principle?

  • Why was the AOA developed, and what role does it play today?

  • How do Articles 7 and 9 differ from one another, and why do taxpayers often conflate the two?

We hope you will be able to join us for this important webcast.

Panelists

  • Mike McDonald, Managing Director, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP

  • Brett Cagliuso, Partner, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP

Date: Thursday, 31 August 2022

Time: 1:00–2:15 p.m. ET New York/Toronto; 10:00–11:15 a.m. PT Los Angeles/Vancouver

Registration: Register for this event.

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You can learn about and register for any EY Global webcast here.

Document ID: 2023-5595

 
 

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