Tax Treaties

Cross-border investment would be seriously impeded if there was a danger that the returns on such investment were taxed twice. The Model Tax Convention and the worlwide network of tax treaties based upon it help to avoid that danger by providing clear consensual rules fo taxing income and capital.

What's new

OECD opens registration for the conference on the 50th anniversary of the OECD Model Tax Convention

29-Apr-2008

29 April 2008 – The OECD has just opened registration and launched the conference website (www.oecd.org/ctp/mtc50years)  for its Conference on the 50th Anniversary of the OECD Model Tax Convention, which will take place in Paris (at the OECD’s new conference centre) on 8-9 September 2008.

Draft contents of the 2008 Update to the Model Tax Convention

21-Apr-2008

From 21 April to 31 May 2008
The OECD Committee on Fiscal Affairs has just released the draft contents of the 2008 update to the OECD Model Tax Convention, which will be finalized in June. The contents of the 2008 update result primarily from reports that have already been released for comments; the draft update also includes, however, a few other technical changes that have not previously been released (see Part I of the report) and on which comments are particularly invited.  Comments on the 2008 update to the Model Tax Convention should be sent to jeffrey.owens@oecd.org by 31 May 2008.

Joint OECD - IFA (India) Conference "At the Crossroads of Tax Co-operation" held in Mumbai, 23-25 January 2008

25-Jan-2008

More than 250 participants met in Mumbai, India, on 23-25 January 2008 to discuss a broad range of international tax issues at the Conference “At the Crossroads of Tax Co-operation:  IFA (India) – OECD” that was jointly organized by the Indian Branch of the International Fiscal Association (IFA) and the Organisation for Economic Co-operation and Development (OECD) to mark the accession of India as observer to the OECD Committee on Fiscal Affairs.

Public comments on discussion draft on Tax Treaty issues related to REITs

23-Jan-2008

On 30 October 2007, the OECD Committee on Fiscal Affairs published a discussion draft  on Tax Treaty issues related to REITs.  The OECD has now published the comments received on that draft.

Public comments on the discussion draft on the tax treaty treatment of services

17-Jan-2008

On 8 December 2006, the OECD published a discussion draft on the proposed changes to the Commentaries on the Model Tax Convention on Income and Capital concerning the tax treaty treatment of services. The OECD has now published the comments received on that draft.

Public comments on revised draft of Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments

06-Nov-2007

On 22 August 2007, the OECD Committee on Fiscal Affairs published a revised public discussion draft  of Part IV (Insurance) of its Report on the Attribution of Profits to Permanent Establishments. The OECD has now published the comments received on that draft.

 

Discussion Draft on Tax Treaty Issues Related to Real Estate Investment Trusts (REITs)

30-Oct-2007

from 30 October 2007 to 15 January 2008
This OECD discussion draft is largely based on the report of an informal technical group of tax officials and experts from the REIT sector which was mandated by the OECD Committee on Fiscal Affairs to prepare an analysis of the issues related to the application of tax treaties to REITs and to present suggestions for additions to the Commentary of the OECD Model Tax Convention.  Comments on this discussion draft should be sent before 15 January 2008.

Public comments on revised draft changes to the commentary on paragraph 2 of Atricle 15

26-Oct-2007

On 12 March 2007, the OECD released revised draft changes to the commentary  on paragraph 2 of Atricle 15 of the Model Tax Convention. The OECD has now published the comments received on that draft.

Comments received on Article 7 of the Model Tax Convention

24-Oct-2007

On 10 April 2007, the OECD Committee on Fiscal Affairs released as a discussion draft  a revised Commentary on Article 7 that takes account of many of the conclusions included in  Parts I, II and III of its Report on the Attribution of Profits to Permanent Establishments. The OECD has now published the comments received on that draft.

Non-discrimination: Comments on the OECD Discussion Draft

08-Oct-2007

On 3 May 2007, the OECD released a public discussion draft  on the Application and Interpretation of Article 24 (Non-discrimination). The OECD has now published the comments received on that draft.

OECD releases revised draft of Part IV (Insurance) of Report on Attribution of Profits to Permanent Establishments

23-Aug-2007

On 22 August, the OECD Committee on Fiscal Affairs published a revised public discussion draft of Part IV (Insurance) of its Report on the Attribution of Profits to Permanent Establishments. The revised draft replaces the original draft of Part IV released in June 2005. Comments may be submitted  by 31 October 2007 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org). A consultation meeting with interested commentators will be held on 26 November 2007.

Tax Reform in India – Achievement and Challenges

04-Jul-2007

Joint Press Briefing Notes by Pier Carlo Padoan, Deputy Secretary General, OECD to the International Tax Conference on "Tax Reform in India – Achievement and Challenges" that was held in Delhi on 3rd July 2007.

The OECD pursues dialogue with business on business restructuring issues

18-Jun-2007

The OECD pursues its dialogue with the business community on the transfer pricing and treaty aspects of Business Restructurings, participates in discussion panels in Washington and Stockholm, and convenes a third meeting of the Business Advisory Group.

Business Engages Top International Tax Officials at OECD Conference in Washington

07-Jun-2007

Nearly 300 U.S. and international executives, government officials and other tax experts convened at the Ronald Reagan Building and International Trade Center in Washington, D.C., for a major two-day conference, which highlighted the work of the OECD in the development of national tax policy and international tax arrangements governing cross-border trade and investment.

Discussion Draft on the Application and Interpretation of the Non-Discrimination Article of the OECD Model Tax Convention

03-May-2007

from 3 May to 31 July 2007
This discussion draft has been prepared by a Working Group mandated by the OECD Committee of Fiscal Affairs to examine the interpretation and application of Article 24 of the OECD Model Tax Convention, which prohibits certain types of discriminatory taxation, with a view to providing greater guidance in this area. The draft deals with practical issues that have arisen in the application of the Article and include proposals for clarification of the Commentary on that article. Comments on this discussion draft should be sent before 31 July 2007.

Discussion draft on a revised Commentary on Article 7 (Business Profits) of the OECD Model Tax Convention

10-Apr-2007

In December 2006, the Committee on Fiscal Affairs released new versions of Parts I, II and III of its Report on the Attribution of Profits to Permanent Establishments, along with a cover note containing an update on the status of that project. In order to provide improved certainty for the interpretation of existing treaties based on the current text of Article 7, a revised Commentary has been prepared and is now being released as a discussion draft for public comment. Comments should be sent if possible before 15 June 2007 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).

Discussion draft on revised proposed changes to the Commentary on paragraph 2 of Article 15 of the OECD Model Tax Convention

from 12-Mar-2007 to 01-Jul-2007

In April 2004, Working Party No. 1 on Tax Conventions and Related Questions released for public comments draft proposals for clarification of the scope of paragraph 2 of Article 15 of the OECD Model Tax Convention with respect to the tax treaty treatment of short-term assignments.  Based on the comments received and a public consultation meeting held in January 2006, revised proposals have been prepared by the Working Party.  Comments on these revised proposals are invited before 1 July 2007.

Arbitration to be an option in cross-border tax disputes, OECD countries agree

07-Feb-2007

OECD countries have agreed to broaden the mechanisms available to companies and individuals involved in cross-border disputes over taxation by introducing the possibility of arbitration if other attempts to resolve disagreements fail.

OECD releases Part I-III of Report on the Attribution of Profits to Permanent Establishments and updates status of project

21-Dec-2006

The OECD Committee on Fiscal Affairs has today published new versions of Parts I, II and III of its Report on the Attribution of Profits to Permanent Establishments, along with a cover note containing an update on the status of the project.  The project, which has been underway for several years, is aimed at achieving a greater consensus on the manner of attributing profits to permanent establishments under Article 7 (Business Profits) of the OECD Model Tax Convention, with a primary goal of avoiding double taxation.

OECD launches project on taxation of collective investment vehicles

18-Dec-2006

An informal consultative group of government and private sector representatives, under the auspices of the OECD’s Centre for Tax Policy and Administration, will tackle the tax treaty issues raised by the large cross-border portfolio investments (more than US$16 trillion) held through collective investment vehicles and global custodians. The project will examine both substantive issues and practical administrative issues related to the application of tax treaties to these investments.

Discussion draft on proposed commentary changes on the tax treaty treatment of services

from 08-Dec-2006 to 16-Feb-2007

The Committee on Fiscal Affairs invites comments on the discussion draft dealing with the tax treaty treatment of services.  The discussion draft includes proposed changes to the Commentary on Articles 5 and 17 of the OECD Model Tax Convention. Comments on the proposed changes should be sent to the Secretariat, to the attention of jeffrey.owens@oecd.org before Friday 17 February 2007.

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The online version of the OECD Model Tax Convention on Income and on Capital (eMTC) is now available.

Electronic Version of the OECD Model Tax Convention