2008 OECD Model : changes to the Commentary on Article 7 and the attribution of profits to permanent establishments

An important aspect of the 2008 Update of the OECD Model pertains to the changes to the Commentary on Art. 7 relating to the attribution of profits to permanent establishments. The changes result in an interim version of the Commentary on Art. 7, pending the adoption of a new version of Art. 7 and a new Commentary, which is expected by 2010. After explaining the background to the updated Commentary on Art. 7, the article examines the major changes made in the 2008 Update.