OECD Model Tax Convention. Condensed Version (2008). Commentary to Art. 7. § 48. P. 131.
1300
Ibid.
1301
Philip Baker, Richard S. Collier. General Report. IFA Cahiers. Vol. 91b. Attribution of Profit to Permanent Establishments. 2006. P. 46.
1302
OECD Model Convention on Income and Capital (2008). Article 7. § 4: «Insofar as it has been customary in a Contracting State to determine the profits to be attributed to a permanent establishment on the basis of an apportionment of the total profits of the enterprise to its various parts, nothing in paragraph 2 shall preclude that Contracting State from determining the profits to be taxed by such an apportionment as may be customary; the method of apportionment adopted shall, however, be such that the result shall be in accordance with the principles contained in this Article».
