On 29/02/2016, interested parties were invited to comment on a discussion draft othat includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds. The OECD is grateful to the commentators for their input and now publishes the comments received.
Responses are invited to the questions included in a consultation document on issues and suggestions related to the impact of the Report on BEPS Action 6 on the tax treaty entitlement of non-CIV funds.
Public comments are invited on a discussion draft that includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds. Comments should be sent by 1 April 2016 at the latest.
As part of the OECD’s work to improve the timeliness of processing and completing mutual agreement procedure (MAP) cases under tax treaties and to enhance the transparency of the MAP process, the OECD makes available annual statistics on the MAP caseloads of all its member countries and of non-OECD economies that agree to provide such statistics.
In-depth discussions took place this week as the international community continues to make progress on the international tax agenda. Officials from more than 100 countries drawing from tax authorities, ministries of finance, development agencies, as well as regional and international organisations, business and civil society came together in a series of meetings hosted by the OECD.
This publication is the ninth 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 15 July 2014, 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.
This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.
On 22 May 2015, interested parties were invited to comment on a revised discussion draft which includes proposals on how to deal with the follow-up work on Action 6 (Prevent treaty abuse) of the BEPS Action Plan.
On 15 May 2015, interested parties were invited to comment on a revised discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan.
Work on the development of the Multilateral Instrument to implement the tax treaty-related Base Erosion and Profit Shifting (BEPS) Action Plan began on 27 May 2015 in Paris. As per the OECD/G20 mandate, the ad hoc Group that will complete the work under Action 15 has been established, with over 80 countries participating.