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BEPS Action 7

Prevent the artificial avoidance of PE status

Description of this action in OECD's Action Plan (July 2013)

Develop changes to the definition of PE to prevent the artificial avoidance of PE status in relation to BEPS, including through the use of commissionaire arrangements and the specific activity exemptions. Work on these issues will also address related profit attribution issues.

Expected output and deadline for this action in OECD's Action Plan (July 2013)

Expected output : Changes to the Model Tax Convention
Deadline : September 2015

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