OECD releases 178 comments to BEPS drafts on treaty abuse and artificial avoidance of PEs

The OECD on January 12 released public comments to discussion drafts under the OECD’s base erosion and profit shifting (BEPS) action plan which deal with the prevention of tax treaty abuse and with the artificial avoidance of permanent establishment (PE) status.

Eighty comment letters were released on the tax treaty abuse discussion draft, which was published on November 21, 2014 under Action 6 of the OECD’s BEPS plan. Ninety-eight comments were released on the draft on avoidance of PE status, published on October 31, 2014 pursuant to Action 7 of the BEPS plan.

Both discussion drafts will be the subject of public hearings to be held in Paris and broadcast over the internet.  The hearing on artificial avoidance of PE status will be held January 21; the hearing on tax treaty abuse will be held January 22.

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