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By Oliver R. Hoor *
On 12 October 2011, the OECD released a discussion draft (the Discussion Draft) on the interpretation and application of Article 5 of the OECD Model Tax Convention (OECD Model) providing a definition of the term permanent establishment (PE) for tax treaty purposes. The Discussion Draft provides for various proposed changes to the Commentary to Article 5 of the OECD Model. This article analyses the most important proposed clarifications in regard to the meaning of the term permanent establishment in a tax treaty context.
Introduction
The main purpose of the PE concept under the OECD Model is to determine the right of a Contracting...
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