OECD releases comments to BEPS discusssion draft on artificial avoidance of PE status

The OECD on June 15 released public comments from 60 organizations on a revised discussion draft under action 7 of the OECD/G20 base erosion and profit shifting (BEPS) plan concerning artificial avoidance of permanent establishment (PE) status.

The comments, numbering 319 pages, address commissionaire structures, the avoidance of PE status through specific activity exemptions, and other issues.

In many of the comments, business representatives have expressed dissatisfaction with the lack of clarity of the proposed rules, stating that the revisions are likely to lead to tax disputes and double taxation.

See:

• Public comments

 

Related MNE Tax articles:

• OECD releases revised BEPS discussion draft on avoidance of PE status

• US disappointed with BEPS plan guidance, say Treasury officials