Published on April 25, 2019
Also available in: French
|Appendix. 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 Capital33 chapters available
Commentaries on the Articles of the Model Convention31 chapters available
Non-OECD Economies’ Positions on the OECD Model Tax Convention30 chapters available
Previous reports related to the Model Tax Convention26 chapters available
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 Tax 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. Updates were published in 1994, 1995, 1997, 2000, 2003, 2005, 2008, 2010, 2014 and 2017.
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, and the text of the Council Recommendation on the Model Tax Convention. A condensed version of the 2017 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.
The 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.