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By Oliver R. Hoor (picture) and Hugues Henaff, Atoz*
On 31 October 2014, the OECD released a discussion draft (the “Discussion Draft”) in regard to Action 7 of the BEPS Action Plan (Prevent the artificial avoidance of the permanent establishment status) for public consultation. The Discussion Draft includes proposals for changes to the definition of permanent establishment (“PE”) found in the OECD Model Convention with a view to broaden its scope. The proposals in the Discussion Draft may have a major impact on global business models and the allocation of taxing rights over business profits. This article outlines the business context of the Discussion Draft, provides an overview of the proposed changes and considers potential implications for Luxembourg...
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