The new article constitutes the second part of the implementation package for the report on the attribution of profits to permanent establishments.
The draft has been revised after initial comments were reviewed at a consultation meeting back in September.
The OECD is inviting comments on the draft article and responses should be received before January 21 2010.
It is expected that once finalised, the new article will be included in the next update of the model tax convention, which is scheduled for the second half of 2010.
More to follow...
