On 20 May 2015, the US Treasury issued five proposed revisions to the US model tax convention for public comment. The revisions are mainly aimed at preventing double non-taxation and are consistent with the G20/OECD Base Erosion and Profit Shifting (BEPS) Project.
Proposed Treaty Rule Addressing So-Called Exempt Permanent Establishments
This proposal includes the addition of a new Paragraph 7 to Article 1 (General Scope) of the model that would deny the tax benefits of the treaty if a re…