The Executive Secretariat of CIAT invites you to download and read section “4.12. Measures to contain the abuse of permanent establishments and commission agents” written by Romeo Carpio Rivera.

The chapter includes a general introduction to the topic, followed by an analysis of the main points of Action 7 of the BEPS Plan. It addresses specific strategies to combat the fraudulent exclusion of Permanent Establishment status through commissionaire agreements, exceptions for preparatory or auxiliary activities, and e-commerce businesses. It also examines practices such as contract splitting among related enterprises. Finally, it highlights the key role of tax information gathering, tax management, and international information exchange, while exploring new alternatives to facilitate the voluntary provision of data.

This is the 35th chapter published as part of the “Manual for the Control of International Tax Planning”, available in English and Spanish. The complete Manual has six sections and is comprised of 42 chapters. New chapters will be published soon.