The OECD services permanent establishment alternative

In this article, the main traits of the services permanent establishment (PE) paragraph of the 2008 OECD Model Convention (hereinafter: the OECD Model) are discussed, including some of the public comments on the discussion draft. With regard to this, the services PE paragraph was introduced in the Commentary in 2008 as an alternative for those countries that may want to opt for such a reduced PE threshold. It is, however, not in the OECD Model itself.