from 12 October 2011 to 10 February 2012
The OECD Committee on Fiscal Affairs invites public comments on proposed changes to the Commentary on Article 5 (Permanent Establishment) of the OECD Model Tax Convention. The purpose of these changes is to clarify how the concept of “permanent establishment” should be applied and interpreted for the purposes of tax treaties concluded on the basis of the OECD Model. Comments on these proposed changes should be sent before 10 February 2012 to Grace Perez-Navarro, Deputy Director, CTPA (

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