Response to the OECD’s discussion draft on Article 5 (Permanent Establishment) the OECD Model Tax Convention

Tax Policy Bulletin ()
On 12 October 2011, the OECD released a public Discussion Draft entitled "Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention". The Discussion Draft proposed 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.