15 March 2005
The OECD Committee on Fiscal Affairs has just released the draft contents of the 2005 update to the OECD Model Tax Convention.
The OECD Model Tax Convention, which is the basic document for the negotiation, application and interpretation of the global network of bilateral tax treaties that govern taxation of cross-border income and capital, is updated periodically to take account of new developments. The last update was approved in January 2003 and the next update will be finalized in the spring of 2005.
As part of the OECD Committee on Fiscal Affair' well-established policy of consulting with business and other interested parties, all the changes to the Articles and the Commentary that will be included in the next update are issued as a draft for a final round of public comments even if most of them have already been released separately.
The contents of the 2005 update result primarily from the following previously released documents:
The update also includes a number of other technical changes to the Model Tax Convention:
The draft does not include changes to the observations and reservations of OECD Member countries and to the positions of non-Member countries that will be included in the Model Tax Convention as part of the final version of the update.
Comments on the 2005 update to the Model Tax Convention should be sent before 27 April 2005. The Committee on Fiscal Affairs will review the update in light of these comments. The comments received will be published on the OECD web site; it is the policy of the OECD to publish all comments received with the name of their author and anyone wishing to remain anonymous or to keep their comments confidential should say so expressly.
Comments on the 2005 update to the Model Tax Convention should be sent before 27 April 2005 to.
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