On the other hand, those supporting such a rule point to various potential administrative benefits given that it is not necessary for source country taxation to absolutely determine whether particular activities are related to the PE or the income involved is attributable to it. That is, those favoring such a rule often prefer it not because they seek particularly broad taxing rights in this area, but because they want to ensure that difficulties of attribution
do not prevent them from in practice exercising what may be well accepted and relatively conservative taxing rights.