Tax treaties

Public Consultation Meeting on the Application of Article 15 of the OECD Model Tax Convention to Short-term Foreing Assignments


The OECD Centre for Tax Policy and Administration (the CTPA) is organising a public consultation meeting on the application of Article 15 of the OECD Model Tax Convention to short-term foreign assignments. That meeting will take place on Monday, 30 January 2006, in Paris at the OECD offices.  The deadline for registration for that meeting was 10 January.  For that reason and since a large number of participants have already registered, registrations for the event can no longer be accepted.

This public consultation follows the release, on 5 April 2004, of a public discussion draft entitled "Proposed Clarification of the Scope of Paragraph 2 of Article 15 of the Model Tax Convention".  That public consultation draft presented proposals aimed at clarifying the scope of paragraph 2 of Article 15 when services are provided through intermediaries. It had been drafted by a small group of delegates of the Working Party No. 1 on Tax Conventions and Related Questions (*).  Since the proposals included in the discussion draft dealt with a number of situations that currently arise in practice, the Working Party had decided to seek the views of interested parties before discussing these proposals.

At its September 2004 meeting, the Working Party briefly examined the comments received on the discussion draft and asked a group of delegates to review the draft proposals in light of these comments.  These delegates have concluded that some changes should be made to the draft proposals on the basis of the comments received.  It also  concluded, however, that it would be useful to have a public consultation meeting with business representatives and other interested parties, and in particular with those who sent comments on the discussion draft, in order to better explain the draft changes, discuss practical cases in light of current country practices and allow participants to present their views. Delegates from the tax administrations of various OECD countries as well as members from the OECD Secretariat will attend that meeting.


(*) That working party is the sub-group of the OECD Committee on Fiscal Affairs which is responsible for updating the OECD Model Tax Convention


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