On 12 June 2015, Insurance Europe published its comments on the permanent establishment (PE) status aspects of the draft Base Erosion and Profit Shifting Action Plan (published by the Organisation for Economic Cooperation and Development (OECD) in May 2015). The draft Action Plan aims to address weakness in the international tax environment including by preventing the artificial avoidance of PE status.  Insurance Europe welcomes the recognition by the OECD that an insurance-specific option in amending the definition of PE is not required. Insurance Europe believes that further refinement of the proposed PE definition is required so that insurers are not subject to a disproportionate compliance burden due to creation of PEs for tax (but not regulatory) purposes.