OECD: Comments on public consultation on model treaty commentary on extractible natural resources

Comments received on public consultation document on proposed changes to commentary on Article 5 of the OECD Model Tax Convention

Comments on public consultation on model treaty commentary

Article Posted date 22 January 2024

The Organisation for Economic Cooperation and Development (OECD) today released comments received on its public consultation document on proposed changes to the commentary on Article 5 of the OECD Model Tax Convention—dealing with the definition of permanent establishment—and its application to extractible natural resources:

Download comments (Zip file – Note: This is a very large file; open from a desktop computer.) 

As explained in the OECD release, the proposed changes result from the work by Working Party 1 on Tax Conventions and Related Questions (the subgroup of the OECD Committee on Fiscal Affairs in charge of the OECD Model Tax Convention) with a view to developing an alternative provision for inclusion in the commentary on Article 5 of the OECD Model Tax Convention on activities in connection with the exploration and exploitation of extractible natural resources, together with related commentary.

 

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