OECD requests for comments on proposals concerning definitions of beneficial owner, emissions trading, and permanent establishment 

October 22: The Organisation for Economic Co-operation and Development (OECD), Committee on Fiscal Affairs, has issued requests for comments on the following revised provisions or discussion drafts:
  • Concerning changes to the meaning of "beneficial owner" in Articles 10, 11 and 12 of the OECD model tax treaty
  • Concerning tax treaty issues related to emissions permits / credits and application of the OECD model tax treaty to cross-border trading of emissions permits
  • Concerning proposals on the application of Article 5 of the OECD model tax treaty on “permanent establishments”

For more information, click on the hyperlinks provided above.



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©2012 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.