Further to the posting of add link, the CFA (at its meeting on 25-26 January) has reviewed the process for finalising the work on the attribution of profits to a PE.  As envisaged, Parts I-III will NOT be finalised in January 2005 and so will retain the status of OECD Discussion Drafts.  Instead further work will be undertaken on the two elements necessary to finalise the project: (1) refining and finalising Parts I-IV (a draft of Part IV which deals with insurance  is to be released in the first half of 2005) ; and (2) revising the Commentary on Article 7 of the OECD Model Tax Convention and considering the language of the Article itself.

These two elements will be done simultaneously, rather than sequentially. To do this efficiently a joint drafting group of WP1 and WP6 delegates will be created to undertake the work on the Commentary. The originally projected completion date of no later than January 2007 should not be affected by the change in the process. The intention is that a package of both Commentary changes and supplementary guidance based on Parts I–IV will be finalised and released at the same time.