OECD Releases Revised Discussion Draft On Permanent Establishments

Jun 5, 2015 | Tax

The initial Action 7 discussion draft on PE’s has been replaced by a revised discussion draft, which largely focusses on expanding the scope of the dependent agent rule and narrowing the scope of the “specific activity” PE exemptions as mentioned under the current Article 5(4) MC. Furthermore, the revised discussion draft proposes an anti-fragmentation rule intended to prevent abuse of PE rules by dividing activities and assigning them to associated enterprises.