KERT

AcronymDefinition
KERTKey Entrepreneurial Risk-Taking (functions)
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4) If the local entity performs KERT functions and therefore attracts to its location assets and risks under the methodology noted in the Discussion Draft--i.
As a practical matter, whether an activity is considered a KERT function will be difficult to determine (e.
If a dependent agent PE is recognised, to what extent can the activities performed locally be considered KERT functions, thus attracting additional assets and risks resulting in taxable income?
Or are the assets and risks related to any PE KERT functions recognised and thus related profit is attributable to the PE?
TEI comments on OECD attribution of profits draft: October 12, 2004
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