The Base Erosion and Profit-Shifting Project, Action 7: A Critical Analysis of the Preparatory/Auxiliary Extension and the New Anti-Fragmentation Rule in the 2017 OECD Model Tax Convention

The PE is a concept under scrutiny. Action 7 of the BEPS Action Plan has laid out a path to defend against artificial avoidance of PE status in light of BEPS concerns that can be associated with mo ...