OECD Releases Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7

On 22 March 2018, the OECD announced the release of additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status). The guidance focuses on high-level general principles that are relevant and applicable in attributing profits to permanent establishments in accordance with applicable treaty provisions. It also provides examples of the attribution of profits to certain types of permanent…