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Discussion draft on New Art. 7 of OECD Model – details

30 August 2008

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Proposed Changes

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OECD

On 7 July 2008, the Committee on Fiscal Affairs (CFA) of the Organisation for Economic and Cooperation and Development released for public discussion a draft concerning Art. 7 (Business profits) of the OECD Model Tax Convention (MTC). This release is part of the implementation package established in the Report on the Attribution of Profits to Permanent Establishments (see). This discussion draft contains a new version of Art. 7, and a revised commentary on the principles for attributing profits to a PE under Art. 7 of the MTC (the Authorized OECD Approach, or AOA). The CFA invited interested parties to send...