The OECD recently released a Discussion Draft, "Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention," which proposes numerous changes affecting application of tax treaty rules regarding the circumstances in which a taxable presence or “permanent establishment” (PE) may be created.
Public comments are invited on the Discussion Draft's proposed changes and amendments. Interested parties are requested to submit their comments before February 10, 2012. PwC has been following closely the OCED's work on the PE issue, and will submit its own response on the various issues discussed.
