BEPS Public Consultation: Prevent the Artificial Avoidance of PE Status


Date: 21 January 2015

Time: 09:30 - 18:00

Location: OECD Conference Centre, Paris



On 31 October 2014, a discussion draft was released on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan.

As part of the transparent and inclusive consultation process mandated by the Action Plan, the Committee on Fiscal Affairs (CFA) invited interested parties to send written comments on this discussion draft.

The OECD is grateful to commentators for the input received which will be discussed during this public consultation.




Morning session (09:30 - 13:00)

Breakdown per item:

Introduction and consultation procedure
Andrew Dawson, Chair of Working Party 1

General presentation of Action 7 and discussion draft
Liselott Kana, Chair of Action 7 Focus Group

General comments from BIAC
Will Morris, BIAC

General comments not related to specific options
Carol Dunahoo, Treaty Policy Working Group
Michael Scharf, Rödl & Partner
Questions and interventions

Options A-D on Art. 5(5) and Art. 5(6)
Catherine Schultz, National Foreign Trade Council
Susana Bokobo, Repsol
Benjamin Shreck, Tax Executives Institute
Questions and interventions


Afternoon session (13:45 - 18:00)

Breakdown per item:

Options E-H on Art. 5(4) changes
Paul Morton, Reed Elsevier Group
Bill Dodwell, Tax Policy Group Deloitte LLP
Questions and interventions

Options I-J: Anti-fragmentation rule for Art. 5(4)
Mary Bennett, International Alliance for Principled Taxation
Questions and interventions

Options K-L: Anti-splitting rule for Art. 5(3)
Vanessa de Saint-Blanquat, MEDEF
Questions and interventions

Options M-N: Special rule for insurance
Mervyn Skeet, Insurance Company Working Group
Stephen Pautard, Association of British Insurers
Questions and intervenions

Attribution of profit issues related to the proposed options
Gary Sprague, Software Coalition
Questions and interventions

Closing remarks
Marlies de Ruiter, OECD

Main entrance of OECD Conference Centre




- Discussion draft

- Compilation of comments

Other meeting documents will be posted on this site as they become available.


Practical information

Enquiries about this meeting should be addressed to