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Revised Commentary on Article 7 of OECD Model released — Orbitax Tax News & Alerts

On 10 April 2007, the OECD Committee on Fiscal Affairs ("Committee") released a discussion draft including a revised Commentary on Art. 7 of the OECD Model Tax Convention, as the first part of the implementation package for its Report on the Attribution of Profits to Permanent Establishments. The revised Commentary takes account of those aspects of the latter Report that do not conflict with the existing Commentary, in order to provide improved certainty for the interpretation of existing treaties based on the current text of Art. 7.

The Committee invited interested parties to comment on the discussion draft preferably before 15 June 2007, or before 1 August 2007 at the latest.

The Committee also announced that it expects to release the second part of the implementation package, i.e. a new version of Art. 7 with accompanying new Commentary, towards the end of 2007.