On December 21^st, 2006, the Committee on Fiscal Affaires of the OECD (OECD CFA) released a new version of the first three parts of its Report on the Attribution of Profits to Permanent Establishments. Part IV was released on August 22nd, 2007. In order to provide maximum certainty on how profits should be attributed to permanent establishments, the Committee has decided that the Report’s conclusions should be reflected in a new version of Art. 7 of the OECD Model Tax Convention (OECD MTC) together with an explanatory Commentary to be used in the negotiation of future tax treaties and of amendments to existing treaties. On April 10^th, 2007, the OECD CFA released a discussion draft covering the first part of an implementation package including the wording of a revised Commentary relevant for the interpretation of the current version of Art. 7 OECD MTC. In the OECD CFA’s view, this package takes into account those aspects of the Report that do not conflict with the existing version of the OECD MTC. It is expected that the new wording will be introduced in an Update of the OECD MTC to be expected in 2008. Stefan Bendlinger analyzes the discussion draft presented by the OECD CFA with a ...