Transfer pricing

Profits of Permanent Establishments - News and Events

 

OECD approves updates to Model Tax Convention, Transfer Pricing Guidelines and Report on Attribution of Profits to Permanent Establishments

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.

 

Public comments on the revised draft of the new Article 7 of the OECD Model Tax Convention

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.

 

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.

 

Draft contents of the 2008 Update to the Model Tax Convention

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.

 

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.

 

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.


 

 

 

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