Additional Guidance on the Attribution of Profits to ...

Additional Guidance on the Attribution of Profits to Permanent Establishments BEPS ACTION 7 March 2018 OECD/G20 Base Erosion and Profit Shifting Project Additional Guidance on the Attribution of Profits to Permanent Establishments, BEPS Action 7 INCLUSIVE FRAMEWORK ON BEPS 2 This document and any map included herein are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Please cite this publication as: OECD (2018), Additional Guidance on the Attribution of Profits to Permanent Establishments, BEPS Action 7, You can copy, download or print OECD content for your own use, and you can include excerpts from OECD publications, databases and multimedia products in your own documents, presentations, blogs, websites and teaching materials, provided that suitable acknowledgement of OECD as source and copyright owner is given.

As to the profit attribution rules, the Report concluded that the changes to the definition of PE in Article 5 of the OECD Model Tax Convention did not require substantive modifications to the existing rules and guidance on attribution of profits to PEs under Article 7 of the OECD Model Tax Convention. However, the Report did mandate the

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