Market leading insight for tax experts
View online issue

The discussion draft on BEPS action 7: reform of PE status

Speed read

The OECD has now released its discussion draft on the reform of the permanent establishment (PE) rules. Although one of the shortest BEPS papers so far released, it contains a number of proposals which, taken together, would lead to a quite fundamental change to the operation of the existing PE rules, with a potentially wide impact on many structures and arrangements currently adopted by MNCs. The proposals, which include widening the dependent agent provisions and narrowing both the independent agent exemptions and the specific activity (e.g. warehouses) exemptions, go beyond the PE areas identified for review in the original BEPS action plan. There is a clear influence in the discussion draft of the BEPS work on the digital economy

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top