Oil and gas coordination centres likely are distinct permanent establishments

Jan de Goede and Ruxandra Vlasceanu suggest under the general OECD commentary principles that unincorporated coordination centres, which provide support to the various oil and gas exploration and production blocks of a joint venture in the same country (such as accounting, administration, finance, human resources, treasury, information and communication, technical support, and supervision activities) (1) are permanent establishments, as their activities are more than preparatory or auxiliary, and (2) are distinct permanent establishments from the exploration and production blocks since such multiple places of business lack geographic and commercial coherence.

Neal Armstrong.  Summary of Jan de Goede and Ruxandra Vlasceanu, "Permanent Establishment Implications for Coordination Centres in the Oil and Gas Industry", Bulletin for International Taxation, September 2013, p. 466 under Treaties – Art. 5.