Tag: Global trading of financial instruments
§ 1.482-9(m)(6) Global dealing operations.
[Reserved] ...
TPG2022 Chapter II paragraph 2.134
In some cases the parties may perform functions jointly, use assets jointly and/or share assumption of risks to such an extent that it is impossible to evaluate their respective contributions in isolation from those of others. As an example, the transactional profit split method can be applied to the global trading of financial instruments by associated enterprises. See in Part III, Section C of the Report on the Attribution of Profits to Permanent Establishments. See Report on the Attribution of Profits to Permanent Establishments (OECD, 2010) ...
TPG2018 Chapter II paragraph 2.134
In some cases the parties may perform functions jointly, use assets jointly and/or share assumption of risks to such an extent that it is impossible to evaluate their respective contributions in isolation from those of others. As an example, the transactional profit split method can be applied to the global trading of financial instruments by associated enterprises. See in Part III, Section C of the Report on the Attribution of Profits to Permanent Establishments. (See the Report on the Attribution of Profits to Permanent Establishments (OECD, 2010) ...