US Treasury Issues Proposed Revisions to the US Model Tax Convention

On 20 May 2015, the US Treasury issued five proposed revisions to the US model tax convention for public comment. The revisions are mainly aimed at preventing double non-taxation and are consistent with the G20/OECD Base Erosion and Profit Shifting (BEPS) Project.

Proposed Treaty Rule Addressing So-Called Exempt Permanent Establishments

This proposal includes the addition of a new Paragraph 7 to Article 1 (General Scope) of the model that would deny the tax benefits of the treaty if a re…