Subject: Public comments on proposed changes to the Commentary on Article 5 (Permanent
Establishment) of the OECD Model Tax Convention
2. I am directed to inform you that the OECD Committee on Fiscal Affairs has invited public
comments on proposed changes to the Commentary on Article 5 (Permanent Establishment)
of the OECD Model Tax Convention. The document can be accessed at
http://www.oecd.org/dataoecd/23/7/48336726.
3. This public discussion draft includes proposals for additions and changes to the
Commentary on Article 5 of the OECD Model Tax Convention resulting from the work of a
subgroup which have recently been presented to the Working Party 1 of OECD for
discussion. Given the practical importance of these proposals, the Committee has decided to
invite public comments on the proposed changes before they are thoroughly discussed by the
Working Party at its meeting at the end of February 2012.
4. India proposes to send its comments on these proposals. However, in order to finalise our
view, we invite comments from all officers of the Department. The comments may kindly be
sent to Kamlesh Varshney, Director (FT&TR-I) by 2nd December 2011 at his email address
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