BEYOND THE FIRM
The value that makes network.
“The allocation of income to the permanent organization in the post-BEPS era”, in Giurisprudenza delle Imposte, No. 3/2018
The article deals with the criteria for allocating income to the permanent organization, taking into account the recent OECD BEPS project and today’s organisational modules of multinational companies characterised by the concentration of functions, fragmentation of production and vertical integration of structures.