Profit Attribution to Permanent Establishments without Personnel under the AOA: A Systematic Analysis of OECD Literature and Recent Developments in Germany

This article analyses approaches to the attribution of profits to permanent establishments without personnel under the Authorised OECD Approach. It reviews the relevant OECD literature and guidance, German legislation and administrative principles, and German case law on the subject. The article aims to identify and propose key principles that should govern the attribution of profits to permanent establishments without personnel and suggests areas for further research.