The attribution of profits to permanent establishments : the 2008 Commentary on Art. 7 of the OECD Model Convention

This contribution analyses the changes made to the Commentary on Art. 7 in the 2008 Update of the OECD Model Convention. It also includes background information on the Authorised OECD Approach for attributing profits to permanent establishments as contained in the OECD Report on the "Attribution of Profits to Permanent Establishments".