: Profits are attributed based on what the PE would have earned if it were a separate entity performing the same functions under the same conditions.
International consensus dictates that a PE should be treated as a "distinct and separate enterprise" for profit determination. The Attribution of Profits to Permanent Establi...
: Determining profit for digital PEs is difficult because revenue is often generated without physical presence or traditional "significant people functions." : Profits are attributed based on what the
: The PE must be allocated sufficient "free" capital to support its assumed risks and assets. Step 2: Determining Profits The Attribution of Profits to Permanent Establi...