Comments received on public consultation document on proposed changes to commentary on Article 5 of the OECD Model Tax Convention
The Organisation for Economic Cooperation and Development (OECD) today released comments received on its 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:
Download comments (Zip file – Note: This is a very large file; open from a desktop computer.)
As explained in the OECD release, the proposed changes result from the work by 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) with a view to developing an alternative provision for inclusion in the commentary on Article 5 of the OECD Model Tax Convention on activities in connection with the exploration and exploitation of extractible natural resources, together with related commentary.