OECD Publishes Comments Received on Attribution of Profits to Permanent Establishments and Revised Guidance on Profit Splits

On 8 September 2016, the OECD published comments received on the following two BEPS discussion drafts:

Attribution of Profits to Permanent Establishments (PE), which deals with the follow-up work in relation to BEPS Action 7 ("Preventing the Artificial Avoidance of PE Status") to provide guidance on how the rules of Article 7 of the OECD Model Tax Convention apply to PEs resulting from the changes made by Action 7 to Article 5 of the OECD Model. In particular, the attribution of profits to…