Insurance EuropeInsurance Europe
Position Paper
Comments on the OECD’s discussion draft on permanent establishments

In the insurance sector in determining attribution of profits to a Permanent Establishments (PE), the key focus is on establishing where the key entrepreneurial risk-taking (“KERT”) functions are undertaken. The 2010 OECD Report on the Attribution of Profits to Permanent Establishments, Part IV recognises that the KERT is with the person that assumes the risk (underwriting).

Published 12 January 2015