Select one or more items in both lists to browse for the relevant content, Browse the selectedThemes and / or countries. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 22 July 2010, including the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back to 1963), the detailed list of conventions between OECD member countries and the background reports. One of the most important parts of the 2010 update to the Model Tax Convention is the replacement of Article 7 of the Model Tax Convention and its Commentary (see the revised discussion draft of a new Article 7 of the OECD Model Tax Convention released on 24 November 2009).

the OECD issued extensive revisions to the OECD Commentary in order to. This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. <<3F19F1DEAD6BE74B992268B6E0EFE3F3>]>> Also available in: oecd model tax convention commentary 2010 pdf. 11.2 Since the publication of the first ambulatory version in 1992, the Model Convention 0000121266 00000 n 0000142059 00000 n

0000126207 00000 n This shorter version contains the full text of the Model Tax Convention on Income and on Capital as adopted by the OECD Council on 22 July 2010. recognition of the growing influence of the Model Convention outside the OECD countries (see below).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. Follow us on Twitter: @OECDtax; For more information, please contact ctp.contact@oecd.org Compared to the previous edition, this edition includes substantial revisions of Article 7 on Business Profits and its related Commentary and other Commentaries that relate to Article 7.

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French, Because the economic and tax environment is constantly changing, articles and commentary in this model convention are periodically updated.

Linking. This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital.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. 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 footnote was deleted because it did not constitute an “observation” as this term is understood for the purposes of the Model Tax Convention and, in fact, simply reflected the position of the Committee on Fiscal Affairs. 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 full-length version. Also available in: Linking. 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, non-member economies’ positions, the Recommendation of the OECD Council, the historical notes and the background reports. OECD Model Tax Convention Mutual Agreement Procedure Statistics for 2018 BEPS Action 6: Prevent treaty abuse BEPS Action 7: Prevent artificial avoidance of permanent establishment status BEPS Action 14: Make dispute resolution mechanisms more effective Latest Documents.

The Model Tax Convention, and the worldwide network of treaties based on it,  provide clear consensual rules for taxing income and capital across countries, while avoiding having income or capital taxed twice by two different countries. recognition of the growing influence of the Model Convention outside the OECD countries (see below).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. The new text reflects the full results of the work of the Committee on Fiscal Affairs on the attribution of profits to permanent establishments, and a 2010 version of the Report on the Attribution of Profits to Permanent Establishments was therefore also adopted by the OECD Council today in order to reflect the replacement of Article 7 in the Model Tax Convention (this new version is an updated version of the report adopted in 2008 which takes account of the new wording of the Article without any substantive changes to the conclusions of the report). Because the economic and tax environment is constantly changing, article and commentaries are constantly under review and are periodically updated. INTRODUCTION 1. s�@m�m-E��e��8d���20�1�-�Z� `qE0�[ vh�ոd. 0000004590 00000 n
xref The Model Convention seeks, wherever possible, to specify for each situation a single rule. 0000000673 00000 n This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 22 July 2010. 0000121998 00000 n This publication is the condensed version of the OECD Model Tax Convention on Income and Capital. In that footnote, France, Spain, Sweden, Switzerland and the United States expressly stated that they agreed with the Committee's conclusions set out in paragraphs 42.11 to 42.13 of the Commentary (which deal with the taxation of services) and did not share the views of some States expressed in paragraphs 42.14 to 42.17. OECD iLibrary Link to this publication: Link to … 22 July 2010 -- The OECD Council has today approved the 2010 Update to the OECD Model Tax Convention.. In addition, a footnote to the observations included in the Commentary on Article 5 has been deleted. Organisation for Economic Co-operation and Development (OECD), © 0000002056 00000 n 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 full-length version. Because the economic and tax environment is constantly changing, articles and commentary in this model convention are periodically updated.

This Condensed Version of the OECD Model Tax Convention contains the full text of the Articles, Commentary, and Country Positions of the Model Tax Convention as it read on 17 July 2008. Also, Appendix I of Volume II, which lists the status of tax conventions between OECD countries, will be replaced as a result of the revision and conclusion of new treaties since 2008. 1651 18 %%EOF

As part of the update, the Report on the Granting of Treaty Benefits with respect to the Income of Collective Investment Vehicles, which was approved by the Committee on 23 April 2010, will be added to the section of Volume II of the electronic and loose-leaf versions of the OECD Model Tax Convention that includes reports on the Model Tax Convention. These changes include in particular the elimination, previously approved by the OECD Council, of all the reservations and positions contrary to the international tax standard on exchange of information that is incorporated in Article 26 (Exchange of Information). French, Purchase the print copy and get immediate access to the content online including option to download, Get immediate access to the content online in all available formats, including PDF and ePub to download. 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. 0000126269 00000 n 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 full-length loose-leaf and electronic versions. Hungarian, Get immediate access to the content online in all available formats, including PDF and ePub to download. x��V{LSW�.�������n��

is the online library of the Organisation for Economic Cooperation and Development (OECD) featuring its books, papers and statistics and is the knowledge base of OECD's analysis and data.

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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 … 0000118625 00000 n Thus today there are 31 non OECD economies that have set out their positions on the Model.

Approval was partially successful, following selected items could not be processed due to error, http://instance.metastore.ingenta.com/content/periodical/20745419, South Georgia and the South Sandwich Islands, Model Tax Convention on Income and on Capital: Condensed Version, Model Tax Convention on Income and on Capital (Full Version), Model Double Taxation Convention on Income and Capital 1977, Draft Double Taxation Convention on Income and Capital 1963.
A revised condensed version of the OECD Model that will include the changes resulting from the update will be published in September 2010.


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