International juridical double taxation – generally defined as the imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical periods – has harmful effects on the international exchange of goods and services and cross-border movements of capital, technology and persons. In recognition of the need to remove this obstacle to the development of economic relations between countries, as well as of the importance of clarifying and standardising the fiscal situation of taxpayers who are engaged in activities in other countries, the OECD Model Convention on Income and on Capital provides a means to settle on a uniform basis the most common problems that arise in the field of international juridical double taxation.
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. Since 1992, the Model has been published in a loose-leaf format to allow the incorporation of these changes; updates were published in 1994, 1995, 1997, 2000, 2003, 2005, 2008 and 2010.
Beginning with the 1997 update, the Model was presented in two volumes. Volume I includes the Introduction and the text of the Articles of the Model and their Commentaries. Volume II includes a section on the positions of non-member countries, reprints of previous reports dealing with tax conventions that the Committee on Fiscal Affairs has adopted since 1977, the list of tax conventions concluded between member countries and the text of the Council Recommendation on the Model Tax Convention. A condensed version of the Model, which includes only the Introduction, the text of the Articles of the Model, their Commentaries and the positions of non-member countries is also available.
Available to download:
2010 Browsable Full Version of the OECD Model Tax Convention
2010 Browsable Condensed Version of the OECD Model Tax Convention
2010 Articles of the Model Tax Convention on Income and on Capital These do not include the Commentary thereon, which is available in the browsable version (see above) and in the published version (see below).
2010 Full Version of the OECD Model Tax Convention
2010 Condensed version of the OECD Model Tax Convention
2008 Condensed version of the OECD Model Tax Convention
2005 Condensed version of the OECD Model Tax Convention