15 September 2017 deadline for responses to OECD discussion draft on attribution of profits to PEs

Posted on

The June 2017 discussion draft sets out high-level general principles for the attribution of profits to PEs in the circumstances addressed by Action 7 of the BEPS Action Plan.

It gives guidance on the following:

  • PEs arising from article 5, paragraph 5 of the OECD model treaty, including examples of a commissionnaire structure for the sale of goods, an online advertising sales structure, and a procurement structure.
  • PEs created as a result of the changes to article 5, paragraph 4, including an example on the attribution of profits to PEs arising from the anti-fragmentation rule included in new paragraph 4.1 of article 5.

Interested parties are reminded to send comments on the proposals in the June 2017 discussion draft by September 15, 2017.

(Further comments are not invited on the 2016 discussion draft and on the PE definitions agreed in Action 7 that were published in the 2015 Final Report.)

June 2017 Discussion Draft here

 

Advertisements

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google+ photo

You are commenting using your Google+ account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s