OECD project on Attribution of Profits to Permanent Establishments : an update

This article provides an update on the current status of the OECD project on the Attribution of Profits to Permanent Establishments, including a discussion of the background to the project, the 2006 OECD Report on the Attribution of Profits to Permanent Establishments, the proposed changes to the existing Commentary on Art. 7 of the OECD Model Treaty, and the issues that may arise from the formulation of a new Art. 7.