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Abstract: 

The attribution of profits of a legal entity among its branches located in numerous jurisdictions has been a topic of much discussion for taxation authorities, as well as the Organization for Economic Cooperation and Development (the “OECD”). Over the past several years, the OECD has been releasing discussion drafts of various parts of its Report on the Attribution of Profits to a Permanent Establishment (the “OECD Report”). The OECD Report is to be divided up into four parts: 1) general considerations; 2) conventional banking; 3) global trading; 4) insurance matters. It is expected that the conclusions raised by the OECD Report will be implemented through the issuance of revised commentary to Article 7 of the OECD Model Convention on Income and on Capital (the “OECD Model”), the projected completion date of which is expected to be no later than January 2007.

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Affiliations:  1: Blake, Cassels & Graydon LLP.