Chris Morgan (KPMG) provides a review of recent international tax developments that matter.
As is regularly the case
these days I am starting my article with an update on the OECD base erosion and profit shifting (BEPS) action plan. Of most significance on 15 May the second and final discussion draft relating to action 7 (the artificial avoidance of permanent establishment (PE) status) was published.
The first discussion draft published on 31 October 2014 set out 14 different options. This new draft builds on those and sets out a single set of specific proposed changes to the PE definition in the OECD model treaty accompanied by corresponding changes to the commentary.
