OECD PE developments
OECD releases a public consultation to update the Commentary on Article 5 of the OECD Model Tax Convention
On 16 November 2023, the Organisation for Economic Co-operation and Development (OECD) released a public consultation on proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources.
The consultation document comprises an alternate provision for both onshore and offshore activities related to the expl…