On 22 March 2018, the OECD released the report Additional Guidance on the Attribution of Profits to Permanent Establishments (BEPS Action 7). This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes to the definition of permanent establishment in the Report on BEPS Action 7 to Article 5 of the OECD Model Tax Convention (MTC). The report only sets out high-level general principles, together with examples on the ..