arbiter
JournalsPricingAccount

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 Taxation2025https://doi.org/10.59403/33y50dsarticle
ABDC B
Weight
0.41

What the paper says

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.

2 citations

Open paper page →

Cite this paper

https://doi.org/https://doi.org/10.59403/33y50ds

Or copy a formatted citation

@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},
}

Paste directly into BibTeX, Zotero, or your reference manager.

Flag this paper

The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach – Part Two

Flags are reviewed by the Arbiter methodology team within 5 business days.

Evidence weight

0.41

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.25 × 0.4 = 0.10
M · momentum0.55 × 0.15 = 0.08
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.