The Artificial Avoidance of Permanent Establishment Status: A Reaction to the BEPS Action 7 Final Report

Journal
International
International Transfer Pricing Journal 2016 (Volume 23), No. 6
The author provides a critical analysis of the issues likely to arise from the Action 7 Final Report under the OECD’s BEPS initiative. Suggestions are also offered that would relieve some of the potentially negative effects.