SET: Attribution of Profits to Permanent Establishments 2008 and 2010 Fall 2011, Two volumes, 700 pages ISBN 978-92-64-09123-8 www.oecd.org/bookshop?9789264091238
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The Report on the Attribution of Profits to Permanent Establishments, approved in its original form by the OECD Council on 17 July 2008, provides guidance on the manner in which the arm’s length principle can be used in determining the profits attributable to a permanent establishment under Article 7 of the OECD Model Tax Convention. In order to fully implement the conclusions of the 2008 Report, the Commitee on Fiscal Affairs decided to draft a new version of Article 7, which now appears in the 2010 update to the Model Tax Convention. The Committee also decided to publish simultaneously with that update a modified 2010 version of the Report, which does not change the conclusions of the 2008 Report but simply deletes obsolete crossreferences and aligns the Report’s wording with the text of the new Article 7 and the revised Transfer Pricing Guidelines.