This book investigates the principles and challenges of attributing business profits to permanent establishments of multinational enterprises for tax purposes. Michael Kobetsky, drawing on extensive experience in international taxation, analyzes Article 7 of the OECD model tax treaty, which governs the allocation of profits to permanent establishments. The work critically examines the limitations of the current arm's length principle in this context and explores formulary apportionment as a potential alternative method for profit allocation. It addresses the complex issues arising from globalization and the increasing prevalence of multinational operations through branches worldwide.

The book is recognized for its in-depth analysis of a critical area in international tax law. It is likely to be valued by tax professionals, policymakers, and academics for its detailed examination of profit attribution principles. The work's focus on the limitations of the arm's length principle and its exploration of alternative methods like formulary apportionment suggest a contribution to ongoing debates in the field. The author's approach provides a thorough review of the existing framework and proposes considerations for future developments in international taxation.