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 email@example.com 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.
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- Posted by Robert Robillard
- On 31 October 2014
- 0 Comments
- Action 7 – Prevent the Artificial Avoidance of PE Status, Base Erosion and Profit Shifting (BEPS), BEPS Action Plan