Is the Arm’s-Length-Principle-Based Authorised OECD Approach to the Attribution of Profits to a Permanent Establishment Losing Its Authority?

From the latest publicly available documents issued by the Inclusive Framework (IF), the author, who is a member of the Steering Group of the IF, argues that the arm’s-length-principle-based authorised OECD approach is fast losing its authority as a principle for profit allocation to permanent establishments.