An applicable tax treaty may modify the concept of a permanent
establishment or a permanent representative.
The (positive or negative) assets that are intended for a perma-
nent establishment’s exclusive use and exploitation are to be
allocated to such permanent establishment. According to the tax
authorities, funds that serve the company as a whole and hold-
ings in other companies are allocable to the head offce, unless
the business assets exclusively support the activities carried out
by the permanent establishment.
For details regarding the allo-
cation of assets and profits to permanent establishments