28 March 2018 OECD releases additional guidance on attribution of profits to a permanent establishment under BEPS Action 7 The Organisation for Economic Co-operation and Development (OECD) released the final Additional Guidance on the Attribution of Profits to a Permanent Establishment (the Report) on March 22, under the Base Erosion and Profit Shifting (BEPS) Action 7 report (Preventing the Artificial Avoidance of Permanent Establishment Status). The Report provides additional guidance on the attribution of profits to permanent establishments (PEs) resulting from the changes to Article 5 of the OECD Model Tax Convention (MTC), as outlined in the final report on BEPS Document ID: 2018-0683 |
