The online commentary on Art. 7 (Business Profits) extensively discusses several important and intricate issues.
It covers a large number of court decisions from many jurisdictions.
The discussion is designed and structured for professionals in law firms, accounting firms, and multinational corporations across the world.
The Commentary is divided into the following chapters:
- Introduction;
- Fixed place permanent establishment;
- Permanent establishment illustrations (Art. 5(2));
- Construction PE and Service PE;
- PE exclusions;
- Dependent agency permanent establishment;
- Subsidiary as a permanent establishment; and
- BEPS Action Item 7 and permanent establishment.