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Model Tax Convention on Income and on Capital: Condensed Version 2014

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Published on August 20, 2014

Also available in: Arabic, French, Turkish

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The OECD Model Tax Convention provides the basis for the negotiation and interpretation of more than 3000 tax treaties that make up a network that co-ordinate the income and corporate tax systems of most countries with the objective of removing tax barriers to cross-border trade and investment.

This publication is the ninth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the full text of the Model Tax Convention on Income and on Capital as accepted on 15 July 2014, but without the historical notes, the detailed list of conventions between OECD member countries and the background reports that are included in the full-length version, which will appear soon. Changes appearing in this edition address such issues as Exchange of Information (Article 26), the meaning of beneficial owner (Aricles 10, 11 and 12), the treatment of sportsment and entertainers (Article 17), treatment of termination payments and other technical issues.

TABLE OF CONTENTS

Foreword
Introduction
Annex. Recommendation of the OECD Council concerning the Model Tax Convention on Income and on Capital
Model Convention with respect to Taxes on Income and on Capital32 chapters available
Title and Preamble
Article 1. Persons covered
Article 2. Taxes covered
Article 3. General definitions
Article 4. Resident
Article 5. Permanent establishment
Article 6. Income from immovable property
Article 7. Business profits
Article 8. Shipping, inland waterways transport and air transport
Article 9. Associated enterprises
Article 10. Dividends
Article 11. Interest
Article 12. Royalties
Article 13. Capital gains
Article 14. Independent personal services – Deleted
Article 15. Income from employment
Article 16. Directors' fees
Article 17. Entertainers and sportspersons
Article 18. Pensions
Article 19. Government service
Article 20. Students
Article 21. Other income
Article 22. Capital
Article 23A. and Article 23B. Exemption method and Credit method
Article 24. Non-discrimination
Article 25. Mutual agreement procedure
Article 26. Exchange of information
Article 27. Assistance in the collection of taxes
Article 28. Members of diplomatic missions and consular posts
Article 29. Territorial extension
Article 30. Entry into force
Article 31. Termination
Commentaries on the Articles of the Model Tax Convention30 chapters available
Commentary on article 1: concerning the persons covered by the Convention
Commentary on article 2: concerning taxes covered by the Convention
Commentary on article 3: concerning general definitions
Commentary on article 4: concerning the definition of resident
Commentary on article 5: concerning the definition of permanent establishment
Commentary on article 6: concerning the taxation of income from immovable property
Commentary on article 7: concerning the taxation of business profits
Commentary on article 8: concerning the taxation of profits from shipping, inland waterways transport and air transport
Commentary on article 9: concerning the taxation of associated enterprises
Commentary on article 10: concerning the taxation of dividends
Commentary on article 11: concerning the taxation of interest
Commentary on article 12: concerning the taxation of royalties
Commentary on article 13: concerning the taxation of capital gains
Commentary on article 14: concerning the taxation of independent personal services
Commentary on article 15: concerning the taxation of income from employment
Commentary on article 16: concerning the taxation of directors' fees
Commentary on article 17: concerning the taxation of entertainers and sportspersons
Commentary on article 18: concerning the taxation of pensions
Commentary on article 19: concerning the taxation of remuneration in respect of government service
Commentary on article 20: concerning the taxation of students
Commentary on article 21: concerning the taxation of other income
Commentary on article 22: concerning the taxation of capital
Commentary on articles 23 A and 23 B: concerning the methods for elimination of double taxation
Commentary on article 24: concerning non-discrimination
Commentary on article 25: concerning the mutual agreement procedure
Commentary on article 26: concerning the exchange of information
Commentary on article 27: concerning the assistance in the collection of taxes
Commentary on article 28: concerning members of diplomatic missions and consular posts
Commentary on article 29: concerning the territorial extension of the convention
Commentary on articles 30 and 31: concerning the entry into force and the termination of the convention
Non-OECD economies’ positions on the OECD Model Tax Convention29 chapters available
Introduction on Non-OECD economies' positions on the OECD Model Tax Convention
Positions on article 1: (persons covered) and its commentary
Positions on article 2: (taxes covered) and its commentary
Positions on article 3: (general definitions) and its commentary
Positions on article 4: (resident) and its commentary
Positions on article 5: (permanent establishment) and its commentary
Positions on article 6: (income from immovable property) and its commentary
Positions on article 7: (business profits) and its commentary
Positions on article 8: (shipping, inland waterways transport and air transport) and its commentary
Positions on article 9: (associated enterprises) and its commentary
Positions on article 10: (dividends) and its commentary
Positions on article 11: (interest) and its commentary
Positions on article 12: (royalties) and its commentary
Positions on article 13: (capital gains) and its commentary
Positions on article 14: (independent personal services) and its commentary
Positions on article 15: (income from employment) and its commentary
Positions on article 16: (directors' fees) and its commentary
Positions on article 17: (entertainers and sportspersons) and its commentary
Positions on article 18: (pensions) and its commentary
Positions on article 19: (government service) and its commentary
Positions on article 20: (students) and its commentary
Positions on article 21: (other income) and its commentary
Positions on article 22: (capital) and its commentary
Positions on articles 23 A and 23 B: (exemption method and credit method) and its commentary
Positions on article 24: (non-discrimination) and its commentary
Positions on article 25: (mutual agreement procedure) and its commentary
Positions on article 26: (exchange of information) and its commentary
Positions on article 28: (members of diplomatic missions and consular posts) and its commentary
Positions on article 29: (territorial extension) and its commentary
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