Public consultation on model treaty commentary on permanent establishments as applied to extractible natural resources
Comments on the public consultation document are due by 4 January 2024.
Comments on the public consultation document are due by 4 January 2024.
The Organisation for Economic Cooperation and Development (OECD) today released a public consultation document on proposed changes to the commentary on Article 5 of the OECD Model Tax Convention—dealing with the definition of permanent establishment—and its application to extractible natural resources:
- Provision on Activities in Connection with the Exploration and Exploitation of Extractible Natural Resources [PDF 305 KB]
As explained in the OECD release, Working Party 1 on Tax Conventions and Related Questions (the subgroup of the OECD Committee on Fiscal Affairs in charge of the OECD Model Tax Convention) has undertaken work on the commentary on Article 5 to develop an alternative provision on activities in connection with the exploration and exploitation of extractible natural resources, together with related commentary.
Comments on the public consultation document are due by 4 January 2024.
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