Model tax convention on income and on capital download. Oecd model, which was approved by the oecd council of ministers on 17 july 2008. 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 are the two most. If you have problems opening the pdf document or viewing pages, download the latest version of adobe acrobat reader. The convention was signed in december 1960 and the oecd officially superseded the oeec in september 1961. This publication is the tenth edition of the condensed version of the oecd model tax convention on income and on capital. Oecd g20 work on base erosion and profit shifting beps the beps action plan identifies 15 specific actions to address gaps and mismatches in the existing international tax standards, including measures to prevent abuse of tax treaties. The extraordinary interest in this 50th anniversary conference is a reflection of the significance achieved by the oecd model over the past five decades. The oecd also has promulgated model convention on the exchange of. The 2014 update was approved by the oecd council on 15 july 2014 and had been approved by the oecd s committee on fiscal affairs on 26 june 2014. Model tax convention on income and on capital 2017 full. 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. Model double taxation convention on income and on capital of the organisation for economic cooperation and development, hereaf ter referred to as the oecd model convention.
This essay tries to summarize and analyze the issues of treaty shopping, which is one of the major problems that countries face today while trying to save their volatile budgets. This full version contains the full text of the model tax convention on income and on capital as it read on 15 july 2014. This 1977 report contains the recommendations of the committee on fiscal affairs for the avoidance of double taxation on income and capital. This site is powered by keepeek 360, digital asset management for business. Pdf treaty shopping and the oecd model tax convention. Models reflects the fact that the united states drew heavily on the work of the oecd in the development of the u. Income derived by a resident of a contracting state from immovable property including income from agriculture or forestry situated in the other contracting state may be taxed in that other state. Model does not represent a lack of support for the work of the oecd in developing and refining its model treaty. Oecds dissemination platform for all published content books, serials and statistics.
At the same time, reprints of a number of previous reports of the committee which had resulted in changes to the model convention were also added. United states model income tax convention of november 15, 2006 convention between the government of the united states of america and the government of for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income the government of the united states of america and. 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. This publication is the condensed version of the oecd model tax convention on income and capital this shorter version contains the full text of the model tax convention, but without the historical notes, the detailed list of tax treaties between oecd member countries and the background reports that are included in the fulllength looseleaf and electronic versions. Oecd ilibrary model tax convention on income and on. This full version contains the full text of the model tax convention as it read on 21 november 2017, including the. The full version of the oecd model tax convention for each edition is published separately. The newest release includes the full text of the mtc as it was released on november 21, 2017, with additional information including articles, commentaries, nonmember economies positions, recommendations of the oecd council and background. Oecd council approves 2017 update to oecd model tax. Model double taxation convention the united nations. This publication is the tenth edition of the full version of the oecd model tax convention on income and on capital.
This full version contains the full text of the model tax convention on income and on capital as it read on 22 july 2010. The 2017 oecd model makes significant changes to many of the operative rules that will impact the availability and scope of treaty benefits for taxpayers resident in countries that enter into revisions to existing treaties or negotiate new treaties based on the oecd model. Oecd ilibrary model double taxation convention on income. Oecd updates model tax convention global transfer pricing alert 2018001 the organisation for economic cooperation and development oecd on december 18 released a revised version of its model income tax convention the 2017 oecd model. 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, which includes both the text of model treaty. Click download or read online button to get model tax convention on income and on capital book now. To the contrary, the strong identity between the provisions of the oecd and u. The full version of the oecd model tax convention is published regularly to reflect updates. Comparison of the proposed changes to the oecd and. 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. Model tax convention on income and on capital 2017 full version this publication is the tenth edition of the full version of the oecd model tax convention on income and on capital. 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. Oecdinternational the ppt in postbeps tax treaty law.
The oecd model is a common reference point for countries engaged in treaty negotiations. The oecd committee on fiscal affairs and its working parties have been working on the proposed changes to the oecd model and the commentary for some years. This site is like a library, use search box in the widget to get ebook that you want. Following the 1957 rome treaties to launch the european economic community, the convention on the organisation for economic cooperation and development was drawn up to reform the oeec. United states model income tax convention of november 15.
Oecd model tax convention 10 oecd chapter iii taxation of income article 6 income from immovable property 1. United states model technical explanation of november 15. 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. This shorter version contains the articles and commentaries of the model tax convention on income and capital as it read on 21 november. Oecd releases 2017 update to the model tax convention.
This paper reports on a study of the tax treaty policy of a group of eleven east african countries. This convention shall apply to persons who are residents of one or both of the contracting states. These model treaties are available on these model treaties are available on the oecd and united nations. This publication is the eighth edition of the full version of the oecd model tax convention on income and on capital. The socalled london and mexico models of the league of nations are clearly in the family tree, but the direct parents were those senior tax officials from european countries who, in 1956, began a collective project aimed at the development of uniform tax treaty provisions. This is the tenth edition of the condensed version of the oecd model tax convention on income and on capital. African tax treaties tend to follow one of two model treaties, an oecd model treaty that favours the interests of capital exporting nations and a united nations model treaty that allows capital importing countries to retain more taxing rights. The update in particular addresses issues regarding beneficial ownership, treatment of. The oecd published the 2014 update of the oecd model convention in july 2014. The web format includes extensive interlinking, making it easy to link from articles to related commentaries.
Chapter 2 international double taxation, tax evasion and aggressive tax planning therefore, following the oecd s statement quoted above which first appeared in the 1992 model,176 the first conclusion that can be drawn is that the complete elimination of double taxation can. These recommendations result from consultation with member countries, following the 1963 draft convention. United states model technical explanation of november 15, 2006. The oecd document needs to differentiate itself from other model tax conventions that the oecd has published on estates and inheritance and gifts and on administrative cooperation. The 2017 model incorporates revisions to treaty related measures following on from outcomes of the oecd beps project, in particular concerning hybrid mismatches, treaty. The web and pdf versions will be available via the oecd ilibrary. The competent authorities of the contracting states shall notify each other of any. Bilateral income tax conventions between countries to alleviate double taxation of income from international investments and activities and to provide. Application of the oecd model tax convention to partnerships,1 the conclusions of. 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 objective of removing tax.
Model bilateral tax treaties international and foreign tax law. The 2017 oecd model provides the basis for negotiation and. Data and research on tax treaties including oecd model tax convention, mutual agreement procedure statistics, prevention of treaty abuse. It contains the full text of the model tax convention on income and capital as it read on 21 november 2017, but without the historical notes and the. On april 25, 2019, the oecd released the 2017 full version of the model tax convention on income and on capital mtc. Profits from the operation of ships in international traffic shall be taxable only in the contracting state in which the place of effective management of the enterprise is situated unless the shipping activities arising from such operation. Download current version in pdf format from the oecd ilibrary. For the purposes of this convention, income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either contracting state shall be considered to be income of a resident of a. 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. The 50th anniversary of the oecd model tax convention. The changes to the existing text of the model tax convention. This shorter version contains the articles and commentaries of the model tax convention on income and. African tax treaties tend to follow one of two model treaties, an oecd model treaty that.
The oecd releases 2017 full version of model tax convention. 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. A building site or construction or installation project constitutes a permanent establishment only if it lasts more than twelve months. Chapter 2 international double taxation, tax evasion and. This convention also shall apply to any identical or substantially similar taxes that are imposed after the date of signature of this convention in addition to, or in place of, the existing taxes. Tax convention on income and on capital2 oecd model. Oecd model tax convention on income and on capital. United states model tax treaty documents the complete texts of the following tax treaty documents are available in adobe pdf format. The 2017 update primarily comprises changes to the oecd model tax convention the oecd model that were approved as part of the beps package or were foreseen as part of the followup work on the treaty related beps measures. The relation between the ppt and tax certainty is mentioned in the international monetary fund imf oecd,report for the g20 finance ministers and. It is being suggested that the imaginable but very realistic scotia. The original oecd limitation on benefits proposal9 was strikingly similar to the us model income tax convention 2006 us model,10 although, as discussed below, it has many of the adaptations now included in the recent us limitation on benefits proposals.
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