BorderCrossings … with EY transfer pricing and tax professionals

Part 2: Profit attribution to PEs: how do transfer pricing principles apply?
Related topics

This webcast, the second in a two-part series, examines the difficulty in applying transfer pricing rules to attribute profits to permanent establishments considering both US and international tax treaties. Under US tax treaties, Article 7 governs profit attribution to permanent establishments and references the arm’s-length principle under Article 9. In response to a lack of clear and consistent interpretation of profit attribution under international tax treaties, the Organisation for Economic Co-operation and Development (OECD) developed the Authorized OECD Approach (AOA).

This webcast will discuss the following questions:

  • How has Article 7 evolved over the decades?
  • To what extent and how does the attribution of profits to permanent establishments under Article 7 apply insights from transfer pricing under the arm’s-length principle?
  • Why was the AOA developed, and what role does it play today?
  • How do Articles 7 and 9 differ from one another, and why do taxpayers often conflate the two?

We hope you will be able to join us for this important webcast.


  • Mike McDonald, Managing Director, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP
  • Brett Cagliuso, Partner, International Tax and Transaction Services – Transfer Pricing, Ernst & Young LLP

EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax.


CPE credits : 1.4


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