OECD Consultations on Attribution of Profits to Permanent Establishments, Revised Guidance on Profit Splits, and Changes to Chapter IX of the Transfer Pricing Guidelines

On 4 July 2016, the OECD published two discussion drafts and one review document for public comment. These include:

Attribution of Profits to Permanent Establishments (PE), which deals with the follow-up work in relation to BEPS Action 7 ("Preventing the Artificial Avoidance of PE Status") to provide guidance on how the rules of Article 7 of the OECD Model Tax Convention apply to PEs resulting from the changes made by Action 7 to Article 5 of the OECD Model. In particular, the attribution …