OECD: Revised Proposals on Article 5 (Permanent Establishment) of the OECD Model Tax Convention

Tax Policy Bulletin ()

The OECD has recently published its revised proposals on Permanent Establishments in a paper entitled “OECD Model Tax Convention: Revised Proposals concerning the Interpretation and Application of Article 5 (Permanent Establishment)”. The document proposes a number of changes affecting the application of the treaty rules which deal with the circumstances in which a taxable presence or “permanent establishment” may be created. This bulletin provides background on the proposals and an analysis of the proposed changes.