INTERPRETATION AND APPLICATION OF ARTICLE 5 …

ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT INTERPRETATION AND APPLICATION OF ARTICLE 5 ( permanent establishment ) OF THE OECD MODEL TAX CONVENTION 12 October 2011 to 10 February 2012 CENTRE FOR TAX POLICY AND ADMINISTRATION 2 12 October 2011 INTERPRETATION AND APPLICATION OF ARTICLE 5 ( permanent establishment ) OF THE OECD MODEL TAX CONVENTION Public discussion draft ARTICLE 5 ( permanent establishment ) of the OECD Model Tax Convention includes the definition of the treaty concept of permanent establishment , which is primarily used for the purpose of the allocation of taxing rights when an enterprise of one State derives business profits from another State.

Article 5 in order to address this issue: Add the following paragraph 3.1 to the Commentary on Article 5: 3.1 The determination of whether or not an enterprise of a Contracting State has a permanent establishment in the other Contracting State must be made independently from the

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  Applications, Interpretation, Article, Permanent, Establishment, Article 5, Permanent establishments, Interpretation and application of article 5

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