Finance Ministry Issues Draft Reg on Attribution of PE Profits

Germany's Federal Ministry of Finance on August 13 released a draft regulation on the attribution of permanent establishment profits; interested parties have until October 11 to comment on the proposed provisions. The regulation will create a German domestic legal basis for article 7 of the OECD model tax treaty and, in particular, with the AOA. It provides a cornerstone of German international tax law and fits perfectly to the government's policy on base erosion and profit shifting