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.
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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