There are important questions for developing countries in evaluating this OECD provision, not just on the underlying policy but also as to how it can be administered effectively. These include whether a developing country is disadvantaged vis-à-vis developed countries and the taxpayers resident in those developed countries by not being able to ascertain the (effectively worldwide) gross revenues of such a person during a particular period. This would be necessary in order to determine whether more than 50% of the gross revenues attributable to active business activities of the enterprise during this period or periods are derived from the services performed in the host (i.e. non-residence) country through that individual. In the latest paper by the UN Tax Committee’s subcommittee on the definition of PEs, the OECD approach has been mentioned as a possibility, but is not the general approach favoured in the paper. The favoured approach effectively reflects the current UN services provision.