BEPS Action 7: Discussion draft on attribution of profits to PEs - 22 July 2016
Read Deloitte’s report on the recently released OECD discussion draft on the attribution of profits to permanent establishments (PEs).
On 4 July 2016, the OECD released a discussion draft on the attribution of profits to permanent establishments (PEs). The draft follows the work previously undertaken by the G20/OECD in relation to preventing the artificial avoidance of PE status (action 7 of the G20/OECD BEPS action plan). It does not reflect, at this stage, a consensus position, but is designed to provide substantive proposals for public review and comment. This issue is also relevant to the operation of Australia’s multinational anti-avoidance law (MAAL) which potentially can deem a PE to exist, and to attribute profits to that PE.