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BEPS action 7: Preventing the artificial avoidance of PE status

Tax Analysis: October 15, 2015/China

As part of the 2015 output, the OECD issued a final report in relation to preventing the artificial avoidance of permanent establishment (PE) status (action 7), which introduces changes to the model treaty. (Tax Analysis:October 15, 2015/China)

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The report builds on proposals put forward in the G20/OECD’s discussion drafts from October 2014 and May 2015 and updates the definition of PE (taxable presence) in article 5 of the OECD model tax treaty and associated commentary.

This newsletter explains the following topics;

  1. Proposals for amendments to article 5 of the OECD model tax treaty
  2. Profit attribution to PEs and interaction with action points on transfer pricing
  3. Deloitte’s Comments and business next steps


>> Click for Japanese [BEPS行動7:恒久的施設(PE)認定の人為的回避の防止]

(219KB, PDF)

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