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PUBLIC COMMENTS RECEIVED ON THE DISCUSSION DRAFT ON THE ATTRIBUTION OF PROFITS TO PERMANENT ESTABLISHMENTS – PART I (GENERAL CONSIDERATIONS)

1. In February 2001 the Committee on Fiscal Affairs of the Organisation for Economic Co-operation and Development (OECD) released a Discussion Draft on the Attribution of Profits to Permanent Establishments (the “Discussion Draft”). The Discussion Draft was prepared by the Steering Group on the Transfer Pricing Guidelines of Working Party No. 6. It is intended as a first step in the development of a consensus among the member countries of the OECD concerning the application of the Transfer Pricing Guidelines to permanent establishments in the context of Article 7 of the OECD Model Tax Convention on Income and on Capital (OECD Model Convention).