Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane Victor are joined by EY managing director Mike McDonald and Mary Bennett, former head of tax treaties and transfer pricing at the OECD. The conversation explores a wealth of topics, including practical aspects of the Authorized OECD Approach (AOA), challenges of attributing profits to PEs and the ongoing debates See more +
Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane Victor are joined by EY managing director Mike McDonald and Mary Bennett, former head of tax treaties and transfer pricing at the OECD. The conversation explores a wealth of topics, including practical aspects of the Authorized OECD Approach (AOA), challenges of attributing profits to PEs and the ongoing debates about the appropriate allocation of profits in cross-border transactions. See less -
