Free Capital Allocation Methods under OECD Model Treaty Article Seven
Free capital allocation under Article 7 assigns enterprise equity to permanent establishments based on people functions and risk-weighted asset ownership.
Authorised OECD Approach Permanent Establishment Profit Attribution Basics
The Authorised OECD Approach attributes permanent establishment profits by hypothesizing a separate legal entity via functional analysis and pricing internal dealings.
Profit Attribution under Authorised OECD Approach for Secondary Permanent Establishment Adjustments in Foreign Venture Restructurings
Applying the Authorised OECD Approach to foreign venture restructurings requires matching physical Significant People Functions with capital allocation to eliminate secondary dividend withholding liabilities.