OECD Report on Attribution of Profits to Permanent Establishments (2008). § 72. P. 26.
1231
Ibid. § 78–79. P. 27.
1232
Philip Baker, Richard S. Collier. General Report. IFA Cahiers. Vol. 91b. Attribution of Profit to Permanent Establishments. 2006. P. 42.
1233
OECD Model Convention on Income and Capital (2008). Article 7. § 2: «Subject to the provisions of paragraph 3, where an enterprise of a Contracting State carries on business in the other Contracting State through a permanent establishment situated therein, there shall in each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities under the same or similar conditions and dealing wholly independently with the enterprise of which it is a permanent establishment».
