Ibid. § 33.

Ibid. § 34.

Rafael Russo, Ed. The Attribution of Profits to Permanent Establishments. The taxation of intra-company dealings. IBFD, 2005. P. 17.

OECD Model Tax Convention. Condensed Version (2008). Commentary to Art. 7. § 34. P. 128.

Ibid. § 36. P. 128.

Ibid. § 37. P. 128.

Ibid. § 38. P. 128.

Ibid. § 40. P. 129.

Philip Baker, Richard S. Collier. General Report. IFA Cahiers. Vol. 91b. Attribution of Profit to Permanent Establishments. 2006. P. 48.

Ibid.

United Nations Model Tax Convention (2011). Art. 7. § 3: «In the determination of the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the business of the permanent establishment including executive and general administrative expenses so incurred, whether in the State in which the permanent establishment is situated or elsewhere. However, no such deduction shall be allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment. Likewise, no account shall be taken, in the determination of the profits of a permanent establishment, for amounts charged (otherwise than towards reimbursement of actual expenses), by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the head office of the enterprise or any of its other offices».