The OECD has just released the discussion draft on the definition of 'permanent establishment' (article 5 of the OECD Model).
The proposed changes clarify, among other topics, the meaning of the 'at the disposal' requirement, the range of contract that may lead to an Agency PE, the use of a home office as a PE and the application of article 5(3) in the context of joint ventures and partnerships.
If you are interested, check the discussion draft here and/or the press release here.
No comments:
Post a Comment