TEI Comments on BEPS Action 7: Preventing the Artificial Avoidance of PE Status

On December 23, 2014, TEI submitted comments to the OECD regarding its Public Discussion Draft on BEPS Action 7: Preventing the Artificial Avoidance of PE Status. TEI's comments focused on the need for any changes to the definition of a permanent establishment in the OECD Model Tax Convention to be clear so that taxpayers and tax authorities may apply the new definition with certainty and avoid unintended tax consequences and controversy.

TEI's comments were prepared under the aegis of TEI's European Direct Tax Committee, whose chair is Nick Hasenoehrl. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

Download the submission.

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