OECD/BEPS: Release of discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status)

On 31 October 2014, OECD has invited public comments on a discussion draft which includes the preliminary results of the work carried on with respect to issues related to the artificial avoidance of PE status and includes proposals for changes to the definition of permanent establishment found in the OECD Model Tax Convention. The Action Plan stresses the need to update the treaty definition of permanent establishment (PE) in order to prevent abuses of that threshold.