Attribution of profits to permanent establishments
The 2018 Master on Transfer Pricing organized by the Commission for International Taxation of the Milan Roll of Chartered Accountants provides a meeting dedicated to the attribution of profits to permanent establishments on 10 January 2019.
Gianni Bitetti will participate as speaker, among others, including: Marco Carrozzino, Officer of the Guardia di Finanza; Claudio Melillo, Milan Roll of Chartered Accountants; Federico Padovan, , Officer of the Guardia di Finanza.
- Art. 7 of OECD Model Tax Convention
- Interaction between art. 7 and art. 9 of OECD Model Tax Convention
- OECD report for 2008-2010 (so-called Authorised OECD Approach)
- Discussion Draft dated June 2017