Political pressure for change -which has manifested itself in the Organisation for Economic Cooperation and Development's (OECD) Base Erosion and Profit Shifting (BEPS) project - is addressing the tax challenges of the digital economy. The political debate has shaken the complacency that changes can simply be made by amending the commentary to the OECD model. In recent years amending the commentary without changing the text of treaties had become something of a tradition. This was certainly the case with the OECD's review of The Interpretation and Application of Article 5 (permanent establishment (PE)) of The OECD Model Tax Convention, began in October 2011, but has now been overtaken by political developments. Several elements of the meaning of permanent establishment are now under the microscope and amendments to the definition in the Model Convention itself are proposed in the OECD Action Plan on BEPS announced in July 2013.
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