Transfer pricing

Attribution of Profits to Permanent Establishments – Current Status of the Project


28/06/2006 -- The Committee on Fiscal Affairs has completed a review of the progress on the project on the attribution of profits to permanent establishments.  It has concluded that its previously announced target of completing the project by January 2007 is no longer feasible in light of the time that has been required to refine the draft Report prepared by Working Party No. 6 and the time that will be required to complete the draft implementation recommendations being prepared by a Joint Drafting Group made up of delegates from Working Party No. 1 and Working Party No. 6.  The Committee expects to release new versions of Part I (General Considerations), Part II (Banking) and Part III (Global Trading) of the Working Party No. 6 Report during the fourth quarter of this year.  It also intends to continue work on a revised version of Part IV (Insurance) with a view towards releasing that as soon as possible after the release of Parts I-III.  These four parts will replace the existing discussion drafts that are currently in the public domain.  The Committee's important work on the implementation phase of the project is also continuing, with the drafting phase now underway after completion of an analysis of Member countries' implementation considerations.  The Committee intends to release for public comment during 2007 a draft version of the changes to the articles and the commentary of the Model Tax Convention arising from this project.


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