Article 5 of the OECD Model Tax Convention

The OECD received public comments on the proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources. This has been announced with a news release on the website of the OECD. On 16 November 2023, the OECD invited public comments on the proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources. These ...

The OECD invites public input on proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources. This has been announced in a news release on the website of the OECD. Further from the news release: Article 5 of the OECD Model Tax Convention on Income and on Capital deals with the definition of permanent establishment. Working Party 1 on Tax Conventions ...

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 ...