Revised Commentary on Article 7 of OECD Model released

On 10 April 2007, the OECD Committee on Fiscal Affairs ("Committee") released a discussion draft including a revised Commentary on Art. 7 of the OECD Model Tax Convention, as the first part of the implementation package for its Report on the Attribution of Profits to Permanent Establishments. The revised Commentary takes account of those aspects of the latter Report that do not conflict with the existing Commentary, in order to provide improved certainty for the interp…