OECD BEPS Action 7: Public Comments Requested
From the OECD website:
“31/10/2014 – Public comments are invited on a discussion draft which includes the preliminary results of the work carried on with respect to issues related to the artificial avoidance of PE status and includes proposals for changes to the definition of permanent establishment found in the OECD Model Tax Convention.
Action 7 of the Action Plan indicates the need to address these issues:
Action 7 – Prevent the Artificial Avoidance of PE Status
Develop changes to the definition of PE to prevent the artificial avoidance of PE status in relation to BEPS, including through the use of commissionnaire arrangements and the specific activity exemptions. Work on these issues will also address related profit attribution issues.
Comments should be sent by 9 January 2015 at the latest (no extension will be granted) and should be sent by email to firstname.lastname@example.org in Word format (in order to facilitate their distribution to government officials). They should be addressed to Marlies de Ruiter, Head, Tax Treaties, Transfer Pricing and Financial Transactions Division, OECD/CTPA […]”
The draft is available here.
DRTP Consulting Inc. solutions go beyond transfer pricing and international tax solutions. This blog post originally appeared at rbrt.ca. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. DRTP Consulting Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek advice and counsel from DRTP Consulting Inc. as required.Posted by drtp On 31 October 2014