The OECD recently released its discussion draft on the reform of the permanent establishment (PE) rules. Richard Collier (PwC) examines the proposals
The PE discussion draft’s stratagem on a number of the areas where rule change is proposed is to offer alternative approaches to deal with the issues identified. The overall tone of the paper is a little more cautious than earlier papers (where typically no such alternative approaches are canvassed). This perhaps reflects the point noted in the paper itself that the proposals in the discussion draft do not represent the consensus views of the OECD but are intended to facilitate analysis and comment by stakeholders. Nonetheless a common trait of all the proposals is clearly to lower the existing PE threshold.
There are five separate...
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