OECD Publishes Comments on Model Tax Convention

On August 11, the Organisation for Economic Co-operation and Development published comments to its newly-released 2017 Model Tax Convention. The Convention contains a proposed new paragraph stating registration for VAT has no bearing on the question of whether an organisation has a "permanent establishment" within a jurisdiction; this clarification is especially timely now that a number of countries that have adopted mandatory VAT registration rules for organisations selling e-services to private consumers. The commentators largely approved of the new paragraph, with many suggesting that the OECD go farther and clarify that optional registration and/or appointing a VAT representative would also have no implications for the permanent establishment question.