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On 12 October 2011, the OECD released a discussion draft (the Discussion Draft) on the interpretation and application of Article 5 of the OECD Model Tax Convention (OECD Model) providing a definition of the term permanent establishment (PE) for tax treaty purposes. More than 40 public comments on the Discussion Draft where submitted, indicating the great importance of the subject. This article provides a concise overview of the public comments on selected issues addressed in the Discussion Draft.
Introduction
As is well known, the main purpose of the PE concept under the OECD Model is to determine the right of a Contracting State to tax the profits of an enterprise which is resident in...
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