Permanent Establishments under the OECD Model (2017) Based on the Principal Role Leading to the Conclusion of Contracts – A Doctrinal and Policy Analysis

Abstract

This article examines the meaning and scope of the expression “playing the principal role leading to the conclusion of contracts” introduced into article 5(5) of the OECD Model (2017). From a policy perspective, the author argues that the 2017 changes realize the overarching principles of appropriate permanent establishment taxation.