Profits of Permanent Establishments

News & Events

News

OECD releases the 2008 Report on the Attribution of Profits to Permanent Establishments

18-Jul-2008

On 17 July 2008, the OECD Council approved the release of the 2008 Report on the Attribution of Profits to Permanent Establishments.  An interim version of Parts I-III of the Report had previously been released in December 2006, and a discussion draft version of Part IV was released in August 2007. The Report was subsequently finalised and approved by the Committee on Fiscal Affairs on 24 June 2008.

The OECD approves the 2008 Update to the Model Tax Convention

18-Jul-2008

On 17 July 2008, the OECD Council approved the contents of the 2008 Update to the OECD Model Tax Convention.  The update had previously been released as a public discussion draft in April 2008.  It was subsequently finalised and approved by the Committee on Fiscal Affairs on 25 June, when the Committee also approved a detailed response to the comments that had been sent on the discussion draft.

Public comments on draft contents of the 2008 Update to the Model Tax Convention

09-Jun-2008

On 21 April 2008, the OECD Committee on Fiscal Affairs published the draft contents of the 2008 Update to the Model Tax Convention.  The OECD has now published the comments received on that draft.

 

Draft contents of the 2008 Update to the Model Tax Convention

21-Apr-2008

From 21 April to 31 May 2008
The OECD Committee on Fiscal Affairs has just released the draft contents of the 2008 update to the OECD Model Tax Convention, which will be finalized in June. The contents of the 2008 update result primarily from reports that have already been released for comments; the draft update also includes, however, a few other technical changes that have not previously been released (see Part I of the report) and on which comments are particularly invited.  Comments on the 2008 update to the Model Tax Convention should be sent to jeffrey.owens@oecd.org by 31 May 2008.

Public comments on revised draft of Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments

06-Nov-2007

On 22 August 2007, the OECD Committee on Fiscal Affairs published a revised public discussion draft  of Part IV (Insurance) of its Report on the Attribution of Profits to Permanent Establishments. The OECD has now published the comments received on that draft.

 

OECD releases revised draft of Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments

23-Aug-2007

On 22 August, the OECD Committee on Fiscal Affairs published a revised public discussion draft of Part IV (Insurance) of its Report on the Attribution of Profits to Permanent Establishments. The revised draft replaces the original draft of Part IV released in June 2005. Comments may be submitted  by 31 October 2007 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org). A consultation meeting with interested commentators will be held on 26 November 2007.

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).

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.

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.


Events

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

from 07-Jul-2008 to 31-Dec-2008

On 24 June 2008, the Committee on Fiscal Affairs approved the Report on Attribution of Profits to Permanent Establishments. It also approved the release, for public comment, of the second part of the implementation package for the conclusions of that Report, i.e. a new version of Article 7 and its Commentary. This new Article and related Commentary changes are now being released as a discussion draft for public comment. Comments should be sent before 31 December 2008 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).



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Publication

Eighth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital

Model Tax Convention on Income and on Capital - Condensed Version (July 2010)