Download or read book Permanent Establishment and the Beps Project (Action 7) written by Carlo Garbarino and published by . This book was released on 2020 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article suggests that the judicial reasoning adopted within judicial trends developed at national level has been used in shaping evolving perspectives about the concept of permanent establishment adopted in the OECD Model. The article strives to achieve fuller comprehension of the issues by the Commentary in 2017, addresses different perspectives which can be adopted about preparatory/auxiliary activities that might prove useful in understanding the anti-fragmentation rule now introduced in Art. 5 § 4.1. of the Model and then focuses on the concept of the Agency-PE in the light of the functional analysis developed by the OECD, with particular attention to the concrete use of the concept of “authority to conclude contracts” within the functional approach now adopted by the OECD Model, particularly in respect to commissionaire strictures.