← Back to results The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part Two Stéphane Austry et al.
Abstract Part One of this article reviewed the purpose and history of permanent establishment (PE) taxation and examined the uneven reception of the Authorised OECD Approach (AOA) across major jurisdictions. Part Two explores the AOA’s practical impact, focusing on banks’ free capital, and addresses concerns about its asymmetry with transfer pricing rules. The article concludes with possible future developments and pathways for refining profit attribution.
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@article{stéphane2025,
title = {{The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part Two}},
author = {Stéphane Austry et al.},
journal = {Bulletin for International Taxation},
year = {2025},
doi = {https://doi.org/https://doi.org/10.59403/33y50ds},
} TY - JOUR
TI - The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part Two
AU - al., Stéphane Austry et
JO - Bulletin for International Taxation
PY - 2025
ER - Stéphane Austry et al. (2025). The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part Two. *Bulletin for International Taxation*. https://doi.org/https://doi.org/10.59403/33y50ds Stéphane Austry et al.. "The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part Two." *Bulletin for International Taxation* (2025). https://doi.org/https://doi.org/10.59403/33y50ds. The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part Two
Stéphane Austry et al. · Bulletin for International Taxation · 2025
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