Tax treaties

Model Tax Convention on Income and on Capital: Condensed Version 2017

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Published on December 18, 2017

Also available in: French

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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.

The full version of the OECD Model Tax Convention for each edition is published separately. It is available in print, PDF and web formats. The web format includes extensive interlinking, making it easy to link from articles to related commentaries. The web and PDF versions will be available via the OECD iLibrary.

TABLE OF CONTENTS

Foreword
Introduction
Model Convention with Respect to Taxes on Income and on Capital
Commentaries on the Articles of the Model Tax Convention33 chapters available
Commentary on Article 1
Commentary on Article 2
Commentary on Article 3
Commentary on Article 4
Commentary on Article 5
Commentary on Article 6
Commentary on Article 7
Commentary on Article 8
Commentary on Article 9
Commentary on Article 10
Commentary on Article 11
Commentary on Article 12
Commentary on Article 13
Commentary on Article 14 [Deleted]
Commentary on Article 15
Commentary on Article 16
Commentary on Article 17
Commentary on Article 18
Commentary on Article 19
Commentary on Article 20
Commentary on Article 21
Commentary on Article 22
Commentary on Articles 23 A and 23 B
Commentary on Article 24
Commentary on Article 25
Commentary on Article 26
Commentary on Article 27
Commentary on Article 28
Commentary on Article 29
Commentary on Article 30
Commentary on Articles 31 and 32
Non-OECD economies' positions on the OECD Model Tax Convention
Recommendation of the OECD Council concerning the Model Tax Convention on Income and on Capital
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About

The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions, plays a crucial role in removing tax related barriers to cross border trade and investment. It is the basis for negotiation and application of bilateral tax treaties between countries, designed to assist business while helping to prevent tax evasion and avoidance. The OECD Model also provides a means for settling on a uniform basis the most common problems that arise in the field of international double taxation. 

The 2017 edition of the OECD Model mainly reflects a consolidation of the treaty-related measures resulting from the work on the OECD/G20 BEPS Project under Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements), Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances), Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status) and Action 14 (Making Dispute Resolution More Effective). 

The OECD Model requires constant review to address the new tax issues that arise in connection with the evolution of the global economy. Working Party No. 1 of the OECD's Committee on Fiscal Affairs meets this need and its work results in regular changes to the Model. Updates were published in 1994, 1995, 1997, 1998, 2000, 2003, 2005, 2008, 2010, 2014, and 2017. 

The full version of the OECD Model Tax Convention, including the Articles, Commentaries, non-member economies’ positions, and historical notes, will be published in 2019.

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