Within international corporate groups, experts such as CSR managers are frequently assigned to other members of the group for knowledge transfer. The first question that arises is whether such an assignment initiates a permanent establishment in accordance with Art 5 para 1 OECD Model Tax Convention (OECD MC). If the general rule is met, the next question arising is the fulfillment of the auxiliary activity clause as defined by Art 5 para 4 OECD MC. This contribution presents reflections on the assessment of CSR management services in the context of Art 5 OECD MC.
