CBDT’s Response To OECD’s Proposed Changes To Commentary On Article 5

The OECD Committee on Fiscal Affairs has proposed important and far-reaching changes to the Commentary on Article 5 (Permanent Establishment) of the OECD Model Tax Convention.

As these changes will have an impact on India, the CBDT has, vide letter dated 8.11.2011, invited comments on the proposals before finalizing its view and sending it as India’s official response to the OECD.