OECD releases additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7
On 22 March 2018, the OECD released the report Additional Guidance on the Attribution of Profits to Permanent Establishments (BEPS Action 7), the OECD announced in a press release published on its website on 22 March 2018. In October 2015, as part of the final BEPS package, the OECD/G20 published the report on Preventing the Artificial Avoidance of Permanent Establishment Status. The Report recommended changes to the definition of permanent ...
Update to OECD Model Tax Convention released
The latest edition of the OECD Model Tax Convention has been released on 18 December 2017, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS), according to an announcement dated 18 December 2017 on the website of the OECD. The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions, plays a crucial role in removing tax related barriers to cross border trade and ...
Public comments received on BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits
On 22 June 2017, interested parties were invited by the OECD to provide comments on two discussion drafts. The first discussion draft on Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent Establishment Status") of the BEPS Action Plan; and a second one on Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 ("Assure ...
OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits
On 22 June 2017 the OECD has released the following discussion drafts: - Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent Establishment Status") of the BEPS Action Plan; - Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the ...