Public Consultation March 2004 : Attribution of Profits to a Permanent Establishment: Revised Part II & III of the Discussion Draft
A two-day public consultation between business representatives, senior government officials and the OECD Secretariat was held on 25th – 26th March 2004 in Geneva hosted by the Swiss Bankers Association. The revised draft was the basis for discussions at a meeting bringing together more than 120 participants, and 24 speakers which led to detailed discussion and excellent interaction. The discussions were confidential but the of the meeting is available.
We take this opportunity to update you on the next stage in the finalisation of the various Reports on the attribution of profits to PEs.
We hope to release Revised versions of Parts I - III for comment in July 2004. Comments will be invited from business particularly on the Revised Parts I and III. The intention is to work informally with banking representatives on drafting and clarification issues on Part III.
Comments received on Parts I - III will be discussed by the OECD Working Party at its meeting on 25-27 October 2004 and the intention is to finalise Parts I-III in early 2005. Once finalised the Reports’ conclusions will be implemented through the appropriate OECD channels, i.e. as amendments to the Model Commentary on Article 7, as background reports to the amendments, and as Guidance in the Transfer Pricing Guidelines.
For further information, contact John Neighbour in the OECD's Centre for Tax Policy and Administration
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