Subcommittee on Modified Permanent Establishment Definition

• Status: Dissolved
• Coordinator: Mr. Stig Sollund (Norway)
• Members
  • Mr. Andrew Dawson (UK)
  • Ms. Habiba Louati (Tunisia)
  • Mr. Ronald van der Merwe (South Africa)
  • Mr. Hans Pijl (Deloitte Belastingadviseurs B.V)
  • Mr. Ofir Levy (Isreal)
  • Mr. Wolfgang Lasars (Germany)
  • Mr. Erwin Silitonga (Indonesia)
  • Mr. Eduardo Zaidenzstat Capnikas (Urguay)
• Mandate
  
  

  To propose improvements in the Commentary on Article 5 of the Model. The work would take into account the OECD Commentaries and put emphasis on useful examples relevant to the specific needs of developing countries.

• Creation: First session of the Committee (2005)
• Dissolution: Fifth session of the Committee (October 2009)
• Activities:
  • Reports
    • Proposal for amendments to article 5 of the United Nations Model Double Taxation Convention between Developed and Developing Countries 2006,
    • Proposal for Amendments to Article 5 of the UN Model, (2007) and corrigendum,
    • Note by the coordinator of the subcommittee on definition of permanent establishment: Further issues relating to permanent establishment, (2008),
    • Note by the coordinator of the subcommittee on definition of permanent establishment: Finalised amendments to current commentary on article 5— permanent establishment, (2008),
    • Definition of Permanent Establishment (Advance Unedited Version) (2009).
• Output:
  • In October 2009, during the fifth session of the Committee a proposal for the redraft of Article 5 was presented and adopted after a few changes and adjustments.