Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention: Response from IBFD Research Staff

Journal
Goede, J.J.P. de; Kaur, D.; Kosters, L.F.; Perdelwitz, A.
OECD
Bulletin for International Taxation 2012 (Volume 66), No. 6
PriceUSD 45

IBFD research staff provide comment on the 2011 OECD discussion draft on the interpretation and application of article 5 (permanent establishments, PEs) of the OECD Model (2010). Following general observations on the concept of PE and the relationship between article 5 and its Commentary, comment is provided on 11 of the issues in the discussion draft.