Treasury Department released statement on attribution of profits under Authorized OECD Approach (AOA)

The Treasury Department released a statement on 7 June 2007 commenting on the Authorized OECD Approach (AOA) for the attribution of profits to permanent establishments. The Treasury Department stated that although it had incorporated the AOA into a few recent US tax treaties, including  Japan andthe United Kingdom, and in thebew US Midel Treaty, it would not apply the AOA to most existing US treaties.

The Treasury Department stated that it disagreed with t…