June 16, 2023
Thursday, June 29 | BorderCrossings . . .With EY transfer pricing and tax professionals (1 pm ET)
Profit attribution to permanent establishments: how do transfer pricing principles apply?
While transfer pricing under the arm’s-length principle is most often applied to transactions between separate legal entities, it can also apply to attribute profits to permanent establishments. Under US tax treaties, Article 7 governs profit attribution to permanent establishments, and references the arm’s-length principle under Article 9. Under the Internal Revenue Code, the tax treatment of branches falls under the “effectively connected income” (ECI) rules.
This webcast will discuss the following questions:
You might be surprised by the answers.
We hope you will be able to join us for this important webcast.
Date: Thursday, June 29, 2023
Time: 1:00–2:15 p.m. ET New York/Toronto; 10:00–11:15 a.m. PT Los Angeles/Vancouver
Registration: View archive here.
CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objectives: Analyze the interaction of US domestic law rules and treaty rules as they apply to permanent establishments. Describe the history of Article 7 interpretation, including the OECD Authorized Approach to profit attribution. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.
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