Discussion draft on a revised Commentary on Article 7 (Business Profits) of the OECD Model Tax Convention

10-Apr-2007

In December 2006, the Committee on Fiscal Affairs released new versions of Parts I, II and III of its Report on the Attribution of Profits to Permanent Establishments, along with a cover note containing an update on the status of that project. In order to provide improved certainty for the interpretation of existing treaties based on the current text of Article 7, a revised Commentary has been prepared and is now being released as a discussion draft for public comment. Comments should be sent if possible before 15 June 2007 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).

First Meeting of the Business Advisory Group

12-Feb-2007

June 2006

A Business Advisory Group was created to provide input from the business community at the early stages of the work on Business Restructurings. The Business Advisory Group met for the first time with the Secretariat in June 2006 in Washington, DC. The creation of the Business Advisory Group is by no means a substitute for a wider consultation process that will take place when the Working Group produces a discussion draft.

Approval of a mandate for the Working Group on Business Restructuring

12-Feb-2007

October 2006

As a follow up to the January 2005 CTPA Roundtable, the Committee on Fiscal Affairs created a Joint Working Group of Delegates from Working Party No. 1 on the Model Tax Convention and Working Party No. 6 on the Taxation of Multinational Enterprises, in order to explore the treaty and transfer pricing aspects of business restructurings.  A detailed mandate for the Group was approved by the Committee on 20 Oct. 2006. The mandate describes the responsibilities of the Group, working methods and timetable. 

OECD releases Part I-III of Report on the Attribution of Profits to Permanent Establishments and updates status of project

21-Dec-2006

The OECD Committee on Fiscal Affairs has today published new versions of Parts I, II and III of its Report on the Attribution of Profits to Permanent Establishments, along with a cover note containing an update on the status of the project.  The project, which has been underway for several years, is aimed at achieving a greater consensus on the manner of attributing profits to permanent establishments under Article 7 (Business Profits) of the OECD Model Tax Convention, with a primary goal of avoiding double taxation.

Comparability: Business Comments on the OECD discussion draft

13-Dec-2006

On 10 May 2006, the OECD released a series of draft issues notes on comparability that was developed by the Committee on Fiscal Affairs' Working Party No. 6, building on experience acquired by countries since the adoption of the Transfer Pricing Guidelines in 1995 and on comments received from the business community in response to an open questionnaire release in 2003.

Transactional Profit Methods: Responses to the OECD Invitation to Comment

18-Sep-2006

On 27 February 2006 the OECD released an open invitation to comment on a number of issues in relation to transactional profit methods described in the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.  Numerous contributions have now been received and will be carefully examined by Working Party No. 6 on the Taxation of Multinational Enterprises.

Attribution of Profits to Permanent Establishments – Current Status of the Project

28-Jun-2006

The Committee on Fiscal Affairs has completed a review of the progress on the project on the attribution of profits to permanent establishments.   It has agreed on next steps for publishing new versions of Parts I - IV of the report and a draft implementation package of proposed changes to the articles and the commentary of the Model Tax Convention.

Consultation with Business on the Attribution of Profits to Permanent Establishments

25-Jan-2006

The OECD’s Centre for Tax Policy and Administration (CTPA) is organising a consultation with business on Part IV (Insurance) of the Discussion Draft on the Attribution of Profits to Permanent Establishments.  That meeting will take place on Friday, 31 March 2006, in Paris at the OECD offices.

Attribution of profits to permanent establishments of insurance companies and current status of the project

30-Sep-2005

On 27 June 2005 the OECD Committee on Fiscal Affairs released for public comment a Discussion Draft on the Attribution of Profits to Permanent Establishments of Insurance Companies.  The contributions that have been received to date are now available.

Available for public comment: Discussion Draft of the Report on the Attribution of Profits to a Permanent Establishment - Part IV (Insurance)

27-Jun-2005

The OECD Committee of Fiscal Affairs has just released for public comment a Discussion Draft of the Report on the attribution of Profits to a Permanent Establishment - Part IV (Insurance). Parts I-III of the Report have already been the subject of extensive consultation but this is the first time that Part IV has been exposed to the public. The deadline for comment is 16 September 2005. Depending on the nature of comments received a decision will be taken on whether it would be useful to have a face to face meeting with commentators.