OECD BEPS Multilateral Instrument
On 18 December 2020, Germany and Pakistan deposited their instrument of ratification of the Multilateral Instrument (MLI) with the Organisation for Economic Co-operation and Development (OECD). Germany confirmed its preliminary positions regarding the PE provisions in which it only chose to apply Article 13(1) Option A (the list of activities, or the combination thereof, is restricted to activities of a preparatory or auxiliary character). Germany also …