Tax treaties

Public comments received on the revised discussion draft on the definition of “permanent establishment” (Article 5) of the OECD Model Tax Convention


12/2/2013 ― On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment a revised discussion draft on the definition of “permanent establishment” (Article 5)  of the OECD Model Tax Convention. The OECD has now published the comments received on this revised discussion draft, which can be downloaded by clicking on the links below. The OECD is grateful to the commentators for their input. Working Party 1 of the Committee on Fiscal Affairs will examine these comments at its February 2013 meeting.


Asea Brown Boveri Ltd


British Private Equity and Venture Capital Association (BVCA)

Chartered Institute of Taxation (CIOT)

Confederation of British Industry (CBI)

Confederation of Swedish Enterprise

Deloitte LLP (United Kingdom)

Ernst & Young Global Services Ltd

European Business Initiative on Taxation (EBIT)

German Association of the Automotive Industry (VDA)

German Electrical and Electronical Manufactures' Association (ZVEI)

German Engineering Federation (VDMA)

German Federation of Tax Advisers 

A. Greenbank & M. Zetter (Macfarlanes LLP)

ICON Wirtschaftstreuhand GmbH

Institute of Chartered Accountants in England and Wales (ICAEW)

International Air Transport Association (IATA)

International Bar Association (IBA)

International Chamber of Commerce (ICC)

Japan Foreign Trade Council (JFTC)

M. E. Mancilla Rendon & M. Astudillo Moya

PwC (Richard Collier)


Tax Executives Institute (TEI)

S. Towers (Deloitte & Touche LLP Singapore)

Treaty Policy Working Group

True Partners Consulting

Volkswagen Aktiengesellschaft



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