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International tax principles for attributing profits to permanent establishments (PE) are found in Art 7 of the OECD Model Tax Convention. Ayant identifié d’importantes différences parmi les pays membres concernant législations internes et interprétations de l’Art. 7, l’OCDE a produit un rapport sur son approche préférée sur l’Attribution de Bénéfice aux ES: Parties I: l’approche générale; II: les banques; III: les activités de commerce. Les Parties I-III ont été complétées en déc. 2006. La Partie IV concerne les Compagnies d'Assurance; un projet révisé a été publié en août 2007.
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18-Jul-2008
On 17 July 2008, the OECD Council approved the release of the final 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.
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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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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.
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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.
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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).
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