Saturday, 25 February 2012

Response to the OECD’s discussion draft on Article 5 (Permanent Establishment) the OECD Model Tax Convention

On 12 October 2011, the OECD released a public Discussion Draft entitled "Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention".  The Discussion Draft proposed a number of changes affecting the application of the treaty rules which deal with the circumstances in which a taxable presence or “permanent establishment” may be created.
PwC’s response to the discussion draft is set out in this bulletin.