OECD published a document in the project BEPS No. 7, "Prevent the artificial avoidance of the PE status," opening the discussion in the area to avoid the avoidance of the status of PE (Permanent Establishment).

Comments to the document should be sent on 09.01.2015. The public consultation will be held on 01.21.2015 r. The report can be downloaded link. 

This topic is crucial for the capital groups operating in international markets in various forms of cooperation. The introduction of new regulations in the proposed form, in many cases, increase the risk of its operations qualify for the category of a fixed base.

In the cited document covers the following topics:

  • dependent agent and other distributors with limited risk, the seller on your behalf and behalf of customers)
  • acts preparatory and secondary (preparatory/auxiliary activities)
  • off related to the maintenance of a fixed place to a delivery of goods, and purchasing products or collecting information,
  • division of complementary activities between the different entities related to the implementation of a single business operation (cohesive business transactions)
  • and other.