Tag: Artificial Avoidance of PE

BEPS Action 7 – Prevent artificial avoidance of PE status

In 2015, the OECD issued the final report under BEPS Action 7 in relation to preventing the artificial avoidance of permanent establishment (PE) status. This report introduces changes to the Model Tax Convention with the purpose of addressing strategies used to avoid having a taxable presence in a country under tax treaties.

OECD Model Tax Convention 2017

OECD Model Tax Convention 2017

A new 2017 edition of the OECD Model Tax Convention has been released today, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS). The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions, plays a crucial role in removing tax related barriers to cross border trade and investment. It is the basis for negotiation and application of bilateral tax treaties between countries, designed to assist business while helping to prevent tax evasion and avoidance. The OECD Model also provides a means for settling on a uniform basis the most common problems that arise in the field of international double taxation. The 2017 edition of the OECD Model mainly reflects a consolidation of the treaty-related measures resulting from the work on the OECD/G20 BEPS Project under Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements), Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances), Action 7 (Preventing the Artificial Avoidance ... Continue to full case