Review of attribution of income to permanent establishments

On 31 October 2012, the Board of Taxation announced the commencement of consultations on a review of the permanent establishment attribution rules. The review was initially announced by the Assistant Treasurer in May 2012 and is expected to be completed by May 2013.
Briefly, at present, Australia adopts the relevant business activity approach in attribution of income to permanent establishments, that is, only actual income or expenses of an entity as a whole are allowed to be allocated. …