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Having identified considerable variation in the practices of OECD and non-OECD countries regarding the attribution of profits to permanent establishments (PE) and in countries’ interpretation of Article 7 (Business Profits) of the OECD Model Tax Convention , the OECD launched a major project to examine how to apply by analogy the arm’s length principle and the guidance contained in the OECD 1995 Transfer Pricing Guidelines to the relationship between a PE and the rest of the enterprise to which it belongs. Find out more...
What's new
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26-Jan-2009
On 7 July 2008, the OECD Committee on Fiscal Affairs called for comments on a draft new Article 7 of the OECD Model Tax Convention and related Commentary changes. The OECD has now published the comments received on that draft.
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08-Sep-2008
In his remarks, Angel Gurría underlined that throughout these five decades, the OECD Model Tax Convention has established itself as the means of settling the most common problems that arise in the field of international taxation on a uniform basis.
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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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