Revised discussion draft on a new article 7 (Business Profits) of the OECD Model Tax Convention.

• Jurisdiction: United States
• Date: 01 January 2010

January 30, 2010

On January 30, 2010, TEI submitted comments on a revised draft of Article 7 and its commentary of the OECD Model Tax Convention. TEI's comments, which took the form of a letter to Jeffrey Owens, Director of the Centre for Tax Policy & Administration of the Organisation for Economic Development in Paris, were submitted under the aegis of its European Direct Tax Committee whose chair is Johann H. Muller of AP Moeller-Maersk.

On 24 November 2009, the Committee on Fiscal Affairs (CFA) of the Organisation for Economic Co-operation and Development (OECD) released a revised draft of a new Article 7 (Business Profits) for the OECD Model Tax Convention as well as related changes to the treaty commentary. The first version of the proposed revisions was released for comment on 7 July 2008, and the Joint Drafting Group on Attribution of Profits of Working Parties No. 1 and 6 held a public consultation meeting on that draft on 17 September 2009. Tax Executives Institute was pleased to submit comments on the first version of the discussion draft and participate in the consultation meeting.

Tax Executives Institute was founded in 1944...