The OECD released on 21 December 2006 a new report on the attribution of profits to permanent establishments (PE). The report released by the OECD contains new versions of Part I (General Considerations), Part II (Banking) and Part III (Global Trading), which replace all previous respective drafts. The OECD have long acknowledged that the current lack of a common interpretation and consistent application of Art. 7 (business profits) can lead to double taxation and non-taxation situations. As such, the OECD decided to examine how the principles developed in the 1995 OECD Transfer Pricing Guidelines should apply in the context of...