The OECD services permanent establishment alternative

Journal
Author
Pijl, H.
Country
OECD
Published Date
Issue
European Taxation 2008 (Volume 48), No. 9
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In this article, the main traits of the services permanent establishment (PE) paragraph of the 2008 OECD Model Convention (hereinafter: the OECD Model) are discussed, including some of the public comments on the discussion draft. With regard to this, the services PE paragraph was introduced in the Commentary in 2008 as an alternative for those countries that may want to opt for such a reduced PE threshold. It is, however, not in the OECD Model itself.