Law360, New York ( January 14, 2015, 11:06 AM EST) -- The Organization for Economic Cooperation and Development has recently published a discussion draft on the portion of its base erosion and profit shifting action plan dealing with permanent establishments and has titled this paper, "Preventing the Artificial Avoidance of PE Status."[1] The title itself illustrates the OECD's view on the matter: taxpayers have taken actions to "artificially" avoid PE status and thereby deprive source countries of deserved tax revenue....
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