BEPS Action 7, Final Report called for changes to the definition of permanent establishment to prevent the artificial avoidance of that status in relation to BEPS, including through the use of commissionaire arrangements and the specific activity exemptions.53

Changes to the meaning of Permanent Establishment proposed in BEPS Action 7 make significant changes to the definition of agency permanent establishments, including the definition of independent agents, as well as, to the operation of the building site or construction or installation project rules, and to the circumstances in which a place or activity is only preparatory or auxiliary.

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