On July 4, 2016, the OECD released a discussion draft with respect to additional guidance on the attribution of profits to permanent establishments.
Action 7 of the BEPS Action Plan (“Preventing the Artificial Avoidance of Permanent Establishment Status”) mandates follow-up work to develop additional guidance on the issue of attribution of profits to permanent establishments. This work is intended to provide guidance on how the rules of Article 7 would apply to permanent establishments resulting from the changes in the Report on Action 7 of the BEPS Action plan to Article 5, as well as take account of the results of the work on other parts of the BEPS Action Plan dealing with transfer pricing, in particular the work related to intangibles, risk and capital.
For a copy of the discussion draft please click on the following link http://www.oecd.org/tax/transfer-pricing/BEPS-discussion-draft-on-the-attribution-of-profits-to-permanent-establishments.pdf
