The text takes into account the two major changes made to the model convention since the book s last edition in 1993, and includes nearly 100 new international cases. The oecd model tax convention universitetet i oslo. The oecd model tax convention contains a tie breaker clause that determines a companys tax residence for the purposes of. This full version contains the full text of the model tax convention on income and on capital as it read on 15 july 2014. Oecd model tax convention 4 oecd chapter iv taxation of capital art. United states model technical explanation of november 15. Tax treaty policy on article 9 of the oecd model scrutinized. Since 1963, the oecd model convention has had wide repercussions on the negotiation, application, and interpretation of tax conventions. This book contains the official text of the oecd model tax convention on income and on capital 2014 condensed version, together with the relevant 2014 updated country tax summaries and treaty charts. Oecd releases 2017 update to the model tax convention. As part of the 2014 update, the reports on tax treaty issues related to emissions permitscredits and.
Negotiations also took into account the model tax convention on income and on capital, published by the organisation for economic cooperation and development the oecd model, and recent tax. Oecd member countries by paolo arginelli and michael dirkis1 8. Oecd s dissemination platform for all published content books, serials and statistics. This publication is the tenth edition of the condensed version of the oecd model tax convention on income and on capital. This book analyses several crucial areas concerning the entitlement to tax treaties. The profits so attributable are normally the profits shown on the books. Rules for a global world by providing evidence on regulatory cooperation in four sectors. Tittle, the new united states model income tax convention 2007 61 bull. Model convention with respect to taxes on income and on capital. And the oecd model tax convention on income and on capital the oecd.
The oecd model convention and the related commentary has an established history. This shorter version contains the full text of the model tax convention as it read on 17 july 2008, but without the historical. The permanent establishment article of the oecd model was originally drafted by oeec working party 1 wp1 comprising representatives from germany and the united kingdom. This full version of the oecd model tax convention contains the full text of the model tax convention on income and on capital as it read on 21 november 2017, including the articles, the commentaries, the non oecd. Model on july 17, 1992, the model double taxation convention on income and capital, and its commentaries, published by the oecd, as updated in 1995 the oecd model, existing u. The authors, in this article, consider the history, context and purpose. Download pdf modeltaxconventiononincomeandoncapital.
United nations model convention draws heavily on the oecd model convention. Oecd revised discussion draft of a new article 7 of the oecd model tax convention paris oecd 2009 oecd tax aspects of transfer pricing within multinational enterprises. Negotiations also took into account the model tax convention on income and on capital, published by the organisation for economic cooperation and development the oecd model, and recent tax treaties concluded by both countries. The model convention seeks, wherever possible, to specify for each situation a single rule.
Model tax convention on income and on capital condensed. This full version contains the full text of the model tax convention on income and on capital as it read on 15 july 2014, including the articles, commentaries, nonmember economies positions, the recommendation of the oecd council, the historical notes now expanded to go back to. Part i of this article examines some of the basic operative assumptions of tax treaties. Model tax convention on income and on capital this publication is the seventh edition of the condensed version of the oecd model tax convention on income and on capital. This full version of the oecd model tax convention contains the full text of the model tax convention on income and on capital as it read on 21 november 2017, including the articles, the commentaries, the non oecd economies positions, the recommendation of the oecd council, the historical notes and the full text of a number of background reports adopted after 1977. Charts, overviews and significant case studies complete the comprehensive explanations on the mechanics of the oecd model and the articles thereof, and make it to a must have for studying the subject. Model tax convention of oecd and its applicability kaustubh s bam keywords. Issues related to article 17 of the oecd model tax convention will be added to the section of the full version of the model tax convention that includes previous reports. History of tax treaties and the permanent establishment. This book is by far the best book on the oecd model tax convention 2010. United states model technical explanation of november 15, 2006. Oecd ilibrary is the online library of the organisation for economic cooperation and development oecd featuring its books, papers and statistics and is the gateway to oecd s analysis and data. Application of the oecd model tax convention to partnerships,1 the conclusions of which have.
The 2010 update to the model tax convention the changes to the existing text of the model tax convention appear in strikethrough for deletions and bold italics for additions a. Primary audiences are policy makers, diplomats, the general public, media and universities. The united nations model convention and the organization for economic cooperation and development oecd model tax convention on income and on capital the oecd model convention. Oecd model tax convention on income and on capital july 2010. Introduction all oecd member countries have given undertakings to ensure that their bilateral income tax treaties conform to the oecd model tax convention. International taxation of permanent establishments by michael. A handbook for assessors and jurisdictions article 26 of the oecd model tax convention on income and on capital and its commentary. However, it also agreed to have an alternative set of. The full version of the oecd model tax convention is published. Oecd, jurisdiction, dtaa, convention, fiscal 6th semester student of b. Oecd ilibrary model tax convention on income and on. This publication is the tenth edition of the full version of the oecd model tax convention on income and on capital.
The 2010 update to the model tax convention 22 july 2010. Oecd ilibrary issues related to article 14 of the oecd. Changes to the title and preamble of the oecd model, as well as to its. United nations ilibrary united nations model double. The league of nations could not foresee the longevity of the principles and structure of its 1928 model tax convention, nor that the bilateral tax treaty. Sourceoecd is the oecd online library of books, periodicals and statistical databases. Based on this pattern, one would anticipate a new edition in 2012 but the oecd announced that the next revised edition of the oecd model tax convention and commentary will not be published until 2014. Oecd releases draft 2017 update to the oecd model tax. Includes text of and commentary on the model tax convention of the oecd clearly explains how to interpret treaty provisions covers other developments, such as internet deals, transfer pricing and eu law new looseleaf format ensures the work is always up to date with developments. The organisation for economic cooperation and development oecd.
This full version contains the full text of the model tax convention as it read on 21 november 2017, including the articles, commentaries, nonmember economies positions, the recommendation of the oecd council, the historical notes and the background reports. This publication is the eighth edition of the full version of the oecd model tax convention on income and on capital. Includes text of and commentary on the model tax convention of the oecd. Oecd has introduced a number of new provisions regarding the entitlement to tax treaties into its model convention as part of the beps project. It also promotes cooperation to deal with tax avoidance and evasion. Model tax convention on income and on capital 2014 full. This shorter version contains the full text of the articles, commentary, and country positions of the model tax convention as it read on 15 july 2005. Replace paragraph 27 of the introduction by the following. Oecd ilibrary model tax convention on income and on capital. It does not include the the historical notes, the detailed list of tax. Oecd model tax convention on income and on capital 28 jan. The interaction of articles 6, 7 and 21 of the 2014 oecd. This states that too strict provisions could, in certain circumstances, prevent cultural exchanges. As discussed in that report, a main source of difficulties is the fact that some.
The web format includes extensive interlinking, making it easy to link from articles to related commentaries. Oecd releases 2017 update to the model tax convention november 28, 2017 in brief the oecd has released the 2017 update to the model tax convention and the related model commentary, largely incorporating the changes approved as part of the base erosion and profit shifting beps package. This shorter version contains the full text of the model tax convention on income and on capital as it read on 22 july 2010, but without the historical notes, the detailed list of conventions between oecd member countries and the background reports that are included in the. The full version contains the full text of the model tax convention as it read on 21 november 2017, including the articles, commentaries, nonmember economies positions, the recommendation of the oecd council, the historical notes and the background reports. Double taxation treaties generally follow the oecd model convention and the official commentary and member comments thereon serve as a guidance as to interpretation by each member country. First, oecd member countries have largely conformed to the model convention when concluding or. Suggested citation sanghavi, dhruv, the interaction of articles 6, 7 and 21 of the 2014 oecd model tax convention. This site is like a library, use search box in the. Oecd model tax convention on income and on capital july 2010 incl commentary download pdf 470 pages oecd model tax convention on income and on capital july 2010 incl commentary. The four case studies follow the same outline to allow for comparison. The model helps to move forward in a way that preserves an appropriate share of taxing rights for developing countries. This shorter version contains the articles and commentaries of the model tax convention on income and capital as it read on 21 november 2017, but without the historical notes and the background reports that are included in the full version. Data and research on tax treaties including oecd model tax. Oecd model convention,all situations previously covered by it would be covered byart.
The oecd model tax convention provides the basis for the negotiation and interpretation of more than 3000 tax treaties that make up a network that coordinate the income and corporate tax systems of most countries with the. The 50th anniversary of the oecd model tax convention. This publication is the sixth edition of the condensed version of the oecd model tax convention on income and capital. Model tax convention on income and on capital 2017 full.
The model tax convention, and the worldwide network of treaties. This site is powered by keepeek 360, digital asset management for business. The web and pdf versions will be available via the oecd. Visit tax notes for all your essential daily tax news and analysis for tax professionals. Article 26 of the oecd model tax convention on income and on. This publication is the ninth edition of the full version of the oecd model tax convention on income and on capital. Model tax convention on income and on capital download. This volume complements the stocktaking report on international regulatory cooperation. The full version of the oecd model tax convention is published regularly to reflect updates. The oecd model convention provides a basis that can be used to draw up a bilateral tax agreement between two states, that seeks to eliminate double taxation. The application of the principal purpose test, limitation on benefits clauses and the. Aug 17, 2010 this publication is the eighth edition of the condensed version of the oecd model tax convention on income and on capital.
The origins of article 55 and 56 of the oecd model. This full version contains the full text of the model tax convention on income and on capital as it read on 22 july 2010. Article 17 of the oecd model tax convention oecd recommendations some of the suggested restrictions are contained in paragraph 2 of the commentary on article 17 of the oecd model tax convention 2014. This condensed version includes the text of the model tax convention as it read on 15 july 2014 after the adoption of the ninth update by the council of the oecd.
This is the ninth edition of the condensed version of the publication entitled model tax convention on income and on capital, first published in 1992 and periodically updated since then. Dec 19, 2012 since 2000, the oecd has published revised editions in 2003, 2005, 2008, and 2010. Publication date 1987 related work oecd model income tax treaties and commentaries. The 2017 pdate primarily comprises changes to the oecd model tax convention u the oecd model that were approved as part of the beps packageor were foreseen as part of the follow up work on the treatyrelated beps measures. A report by the committee on fiscal affairs on the proposed regulations under section 482 irc paris oecd 1993. In fact, the work on a first model convention was commenced in 1921 by the league of nations and led to the drawing up in 1928 of the first model bilateral convention and, finally, to the model conventions of mexico 1943 and london. Download pdf the oecd model convention and its update. Model double taxation convention the united nations. Click download or read online button to get taxation of capital gains under the oecd model convention book now. Application of the oecd model tax convention to partnerships, 1 the conclusions of which have been incorporated below and in the commentary on various other provisions of the model tax convention. A new us model treaty the 1996 united states model income tax convention us mc was released in september 1996.