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OECD Article 5 PE Changes Analysis by Dede Kurniawan is a document available to read on EtoBox.

What is OECD Article 5 PE Changes Analysis about?

1. The document provides comments on proposed changes to the interpretation and application of Article 5 of the OECD Model Convention regarding the definition of a permanent establishment. 2. It argues that the separate entity approach requires a strict concept of a fixed place of business in order to treat a PE as a separate entity. It proposes additional objective criteria to define a fixed place of business, including a local presence requirement, temporal requirement of at least one year of activity,

Author

Dede Kurniawan

Language

EN