On 15 May 2015, the OECD published a follow up discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the Base Erosion and Profiting Shifting (BEPS) Project.
The OECD released the first discussion draft on Action 7 on 31 October 2014, which described a number of PE avoidance strategies and included a number of alternative options on how to deal with these strategies. Based on the comments that were received on that discussion draft and the interventions at a public c…