Seeking Permanent Establishment Clarity: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking at the mountain of comments the OECD got about global workforce mobility and permanent establishments. Surprise, surprise! Folks want/need more guidance. Plus, an advocate general opinion in the EU’s top court on Stellantis’ TP adjustments and VAT, and more.

The OECD dumped the whole trove of 64 comments that it got as it works on global mobility guidance.

Among the top topics, as always, was permanent establishment—when it gets triggered, how to allocate profits, and what it means for transfer pricing.

Issue number ...