OECD discussion draft on Article 5 (Permanent Establishment) of the OECD Model Tax Convention

Tax Policy Bulletin ()
The OECD has recently published a public discussion draft entitled Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention. The discussion draft 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.