Committee on Fiscal Affairs Approves Revised Article 26 on Information Exchange

22-juil.-2004

Following a comprehensive review, the Committee has approved a revised Article 26 of the Model Tax Convention. The review took into account recent developments such as the ideal standard of access to bank information (see 2000 Report ) and more generally was intended to bring Article 26 in line with current country practices and the 2002 Model Agreement .

Proposed Clarification of the Permanent Establishment Definition

13-avr.-2004

Working Party No. 1 on Tax Conventions and Related Questions  has been invited, by its delegates and representatives of the business community, to expressly include in the Commentary to the OECD Model Tax Convention some widely-accepted interpretations related to the permanent establishment concept. The proposals included in this public discussion draft are therefore intended to clarify some basic aspects of that concept. Comments on these proposals should be sent before 30 June 2004.

Taxation of Income from International Transport: Updating of the Commentary to the OECD Model Tax Convention

13-avr.-2004

In consultation with representatives of the airline and shipping industries, Working Party No. 1 of the OECD Committee on Fiscal Affairs has revised the Commentary on Article 8 of the Model Tax Convention (which deals with income from the operation of ships and aircraft in international traffic) in order to take account of the evolution in international transport activities. This note includes these changes.  Comments on the note should be sent before 30 June 2004 to jeffrey.owens@oecd.org and jacques.sasseville@oecd.org

Discussion Draft on the Proposed Clarification of the Scope of Paragraph 2 of Article 15 of the Model Tax Convention

05-avr.-2004

Paragraph 2 of Article 15 of the OECD Model Tax Convention provides that a non-resident employee who performs services in a country is not subject to tax in that country under certain circumstances. The exact scope of the paragraph is sometimes unclear when services are provided through intermediaries. This discussion draft includes draft proposals for clarification of the Commentary on Article 15 that have been prepared by a small drafting group (these draft proposals have not yet been discussed by Working Party No. 1 on Tax Conventions and Related Questions, which is the sub-group of the OECD Committee on Fiscal Affairs responsible for updating the OECD Model Tax Convention).

Memorandum of Understanding signed at the OECD-Vienna Multilateral Tax Centre

11-mars-2004

Ambassador Ulrich Stacher of Austria and Mr Jeffrey Owens, Director of the Centre for Tax Policy and Administration, signed a memorandum of understanding on the implementation of the multilateral tax programme at the OECD-Vienna Multilateral Tax Centre. 

Discussion Draft on Tax Treaty Issues Related to Cross-Border Pensions

Ageing populations in OECD countries, the increasing mobility of workers and, more generally, the globalisation of the economy have increased the importance of the tax issues arising from situations where cross-border pension contributions or benefits are paid. Tax treaties have an important role to play in solving such issues. Working Party No. 1, the subsidiary body of the OECD Committee on Fiscal Affairs that deals with tax treaty issues, has prepared a public discussion draft that seeks to provide more guidance on the tax problems related to cross-border pension arrangements, contributions and benefits. Comments on this draft should be sent to the OECD before 15 January 2004.