Attribution of Free Capital and Interest Expenses to a Permanent Establishment under the ‘Authorised OECD Approach’ for non-financial Enterprises What is the Impact of Interest Attribution on the Allocation of Profits under the new Approach?
This thesis aims at analysing and discussing the rules and opportunities of using permanent establishment within financial structures. Financing structures between related parties can be seen as one of the most common tax planning tools for MNE´s. This planning is tackled by thin capitalization rules and is also under the observation of the transfer pricing guidelines. Whereas permanent establishm