The UN has published an agenda paper on the proposed BEPS-related changes to the UN Model tax treaty as part of the fourteenth session of the Committee of Experts on International Cooperation in Tax Matters held 3 to 6 April 2017. The main points include possible changes relating to permanent establishments (Article 5), including:
- Adding anti-contract splitting rules;
- Eliminating the "same or connected project" provision regarding service PEs;
- Amending the PE exceptions, so that the all cate…