15 December 2017

India's positions on permanent establishment in OECD's 2017 Update to Model Tax Convention and Commentary discussed

The Organisation for Economic Co-operation and Development (OECD) approved the contents of the 2017 Update to the OECD Model Tax Convention (MTC) and Commentary (the OECD Model) on November 21. Like the previous updates, the 2017 Update contains the positions of OECD and non-OECD member countries, including those of India, on the OECD MTC and its Commentary. India's positions to the 2017 Update are mainly on Permanent Establishment (PE), Mutual Agreement Procedure (MAP) and on certain other miscellaneous provisions, such as the tie-breaker rule for residence of non-individuals, and tax treaty eligibility for transparent entities, among others.

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2017-2123

Document ID: 2017-2123