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Having identified considerable variation in the practices of OECD and non-OECD countries regarding the attribution of profits to permanent establishments (PE) and in countries’ interpretation of Article 7 (Business Profits) of the OECD Model Tax Convention, the OECD launched a major project to examine how to apply by analogy the arm’s length principle and the guidance contained in the OECD 1995 Transfer Pricing Guidelines to the relationship between a PE and the rest of the enterprise to which it belongs. Find out more...
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22-Jul-2010
The OECD Council today approved the 2010 updates to the OECD’s Model Tax Convention, the 1995 Transfer Pricing Guidelines and the 2008 Report on the Attribution of Profits to Permanent Establishments. The updates are the result of several years of work to improve these core OECD instruments in the area of international taxation.
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21-May-2010
The OECD Committee on Fiscal Affairs has just released the draft contents of the next update to the OECD Model Tax Convention (the 2010 Update) prepared by Working Party 1 of the Committee. The update will be submitted for approval of the Committee in June and the OECD Council in July. As all the substantive contents of the 2010 Update have previously been released for comments through various discussion drafts, this draft is released for information only and not for additional comments.
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28-Jan-2010
On 24 November 2009, the OECD Committee on Fiscal Affairs released for public comment a proposed draft of the new Article 7 of the Model Tax Convention. The OECD has now published the comments received on this consultation draft.
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25-Nov-2009
24-Nov-2009 to 21-Jan-2010
On 24 November 2009, the OECD Committee on Fiscal Affairs approved the release, for public comment, of a revised draft of a new Article 7 (Business Profits) of the OECD Model Tax Convention and of related Commentary changes. The new Article 7 is aimed at ensuring the full application of the Report on Attribution of Profits to Permanent Establishments that the OECD adopted in 2008. Comments on the revised draft should be sent before 21 January 2010 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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26-Jan-2009
On 7 July 2008, the OECD Committee on Fiscal Affairs called for comments on a draft new Article 7 of the OECD Model Tax Convention and related Commentary changes. The OECD has now published the comments received on that draft.
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