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.
Quantifying Capital Buffer Compression and Solvency Rules under Restructured Ancillary Direct Clearing Scope Treaties
Restructuring ancillary direct clearing scope treaties compresses risk weighted trade exposures from 20 percent to 2 percent under SA CCR rules.
Significant People Functions in Permanent Establishment Asset Allocation
Economic asset allocation to permanent establishments depends on physical employee risk-taking functions rather than head office legal registration.
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.