Transcription of BEPS Action 7 Additional Guidance on Attribution …
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BEPS Action 7 Additional Guidance on Attribution …
Base Erosion and Profit Shifting (BEPS) Public Discussion Draft BEPS Action 7 Additional Guidance on Attribution of profits to permanent Establishments 22 June-15 September 2017 DISCUSSION DRAFT ON Additional Guidance ON THE Attribution OF profits TO permanent ESTABLISHMENTS The Report on Action 7 of the BEPS Action Plan (Preventing the Artificial Avoidance of permanent establishment Status) mandated the development of Additional Guidance on how the rules of Article 7 of the OECD Model Tax Convention would apply to PEs resulting from the changes in the Report, in particular for PEs outside the financial sector. The Report indicated that there is also a need to take account of the results of the work on other parts of the BEPS Action Plan dealing with transfer pricing, in particular the work related to intangibles, risk and capital. Importantly, the Report explicitly stated that the changes to Article 5 of the Model Tax Convention do not require substantive modifications to the existing rules and Guidance on the Attribution of profits to permanent establishments under Article 7 (see paragraph 19-20 of the Report).
DISCUSSION DRAFT ON ADDITIONAL GUIDANCE ON THE ATTRIBUTION OF PROFITS TO PERMANENT ESTABLISHMENTS The Report on Action 7 of the BEPS Action Plan (Preventing the Artificial Avoidance of Permanent
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Attribution of Profits, Attribution of Profits to Permanent Establishments, Permanent establishments, Permanent, Attribution, LB&I International Practice Service Transaction Unit, Income Tax Act 2007, Taxation (International and Other Provisions) Act, Departmental interpretation and practice notes, Guidelines for requesting Mutual, Guidelines for requesting Mutual Agreement Procedure