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BEPS Action Item 7 and Independent Agents

 By: Dr. Amar Mehta  -  December 8, 2016

Introduction

The current Art. 5(6) of the OECD Model Convention excludes from the definition of a permanent establishment (PE) business dealings through a broker, commission agent or any other agents of independent status, provided that such persons are acting in the ordinary course of their businesses.

For an agent to be of an independent status, all of the following conditions must be satisfied:

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