OECD releases a discussion draft on BEPS Action 7

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 […]

Written By ACT Team

On July 8, 2016
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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

How can we help?  

For further information, please contact one of the firm’s tax partners, Stephen Balzan on [email protected] or Elaine Camilleri [email protected]. ACT can help you understand the changes to the tax rules and how these can impact your business.  

Apart from its offices in St. Julian’s Malta, ACT operates from a second office in Gozo, which is situated in the capital city of Victoria.  For an appointment in our Gozo office, please call on 00356 21378672 or send us an email on [email protected].