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The United States Council for International Business (USCIB) welcomes the opportunity to provide comments on the Public discussion draft related to the Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention. The USCIB appreciates the hard work of the Working Group and the thoughtful guidance provided by the discussion draft, but notes that additional guidance or clarification is needed in certain areas. The USCIB promotes open markets, competitiveness, and innovation, and its members include top U.S.-based global companies and professional services firms. The main use of the permanent establishment (PE) concept is to determine the rights of a Contracting State to tax the business profits of an enterprise of the other Contracting State. The USCIB believes that the updating of the Commentary will be of great benefit to business and tax administrators, but notes that there is an urgent need to revisit the relationship between PE, Business Profits, Associated Enterprises (transfer pricing), and Mutual Agreement articles of the Model Convention.