Transfer pricing

Discussion draft released on Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments (revised)


In June 2005, the Committee on Fiscal Affairs released for public comment an initial discussion draft of Part IV (Insurance) of the Report on the Attribution of Profits to Permanent Establishments. A consultation meeting with representatives of the insurance industry and other interested parties was held on 31 March 2006. The tax administrations from 14 countries and over 40 private sector participants were present at the consultation.


The Committee has today released a revised discussion draft of Part IV which replaces the June 2005 version. The Committee decided that this revised draft should be publicly released for comments with a view to continuing the discussion of this proposed part of the Report in light of comments from interested parties. The Committee also intends to hold a consultation meeting with interested commentators on this revised discussion draft in Paris on Monday, 26 November 2007. Interested parties are invited to send their written comments on this revised discussion draft by 31 October 2007. Commentators who also wish to participate in the consultation meeting through the presentation of oral comments may include a request to do so in their written submission.


The Committee intends to finalise Part IV after the public consultation and to publish it, along with the already completed versions of Parts I-III issued in December 2006, as a final Report.


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