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Cross-border investment would be seriously impeded if there was a danger that the returns on such investment were taxed twice. The OECD Model Tax Convention and the worldwide network of tax treaties based upon it help to avoid that danger by providing clear consensual rules for taxing income and capital.
What's new
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11-Jan-2012
Ms. Marlies de Ruiter has been appointed Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division of the OECD's Center for Tax Policy and Administration to replace Mary Bennett. She will take up her duties on 1 February 2012.
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08-Dec-2011
The OECD has released statistics on the mutual agreement procedure (MAP) caseloads of OECD member countries and certain non-OECD economies for the 2010 reporting period. These statistics reveal a slight decrease in the total number of open MAP cases reported by OECD member countries as compared to the 2009 reporting period. The collection of these statistics forms part of the OECD's continuing work to improve the timeliness of processing and completing MAP cases under tax treaties and to enhance the transparency of the MAP process.
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16-Nov-2011
On 31 May 2011, the OECD Committee on Fiscal Affairs released for public comment a discussion draft on the application of the provisions of the OECD Model Tax Convention to the cross-border trading of emissions permits. The OECD has now published the comments received on this consultation draft.
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12-Oct-2011
from 12 October 2011 to 10 February 2012
The OECD Committee on Fiscal Affairs invites public comments on proposed changes to the Commentary on Article 5 (Permanent Establishment) of the OECD Model Tax Convention. The purpose of these changes is to clarify how the concept of “permanent establishment” should be applied and interpreted for the purposes of tax treaties concluded on the basis of the OECD Model. Comments on these proposed changes should be sent before 10 February 2012 to Grace Perez-Navarro, Deputy Director, CTPA (grace.perez-navarro@oecd.org).
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29-Aug-2011
The OECD’s Centre for Tax Policy and Administration (CTPA) is pleased to announce that Mr. Joseph Andrus has been appointed Head of the Transfer Pricing Unit within the CTPA’s Tax Treaty, Transfer Pricing and Financial Transactions Division. He will take up his position on 1st October 2011 following the departure of Ms. Caroline Silberztein.
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22-Jul-2011
On 29 April 2011, the OECD Committee on Fiscal Affairs released for public comment a discussion draft on the meaning of “beneficial owner” in the OECD Model Tax Convention. The OECD has now published the comments received on this consultation draft.
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31-May-2011
The OECD Committee on Fiscal Affairs invites public comments on its preliminary analysis of the tax treaty issues related to the trading of emissions permits. This analysis addresses the application of the provisions of the OECD Model Tax Convention to profits and gains arising from the cross-border trading of emissions permits. Comments on this analysis should be sent before 30 October 2011 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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29-Apr-2011
The OECD Committee on Fiscal Affairs invites public comments on proposed changes to the Commentary on Articles 10, 11 and 12 of the OECD Model Tax Convention. The purpose of these changes is to clarify how the term “beneficial owner”, which is used in these Articles, should be interpreted. Comments on these proposed changes should be sent before 15 July 2011 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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26-Nov-2010
As part of its ongoing work to improve the timeliness of processing and completing mutual agreement procedure (MAP) cases under tax treaties and to enhance the transparency of the MAP process, the OECD has made available statistics on MAP caseloads for OECD member countries and certain non-OECD economies for the 2008 and 2009 reporting periods. The statistics for these reporting periods now divide MAP cases into cases with OECD member countries and cases with non-OECD economies for countries that have provided that information.
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16-Sep-2010
On 8 February 2010 the OECD released for public comment draft documentation (Implementation Package) for implementing a streamlined procedure for portfolio investors to claim reductions in withholding rates pursuant to tax treaties or domestic law in the source country. The draft documentation was developed to provide standardised documentation that could be used by countries that wish to adopt the “best practices” described in a report released by the OECD on 12 January 2009. The OECD has now published the comments received on this draft Implementation Package.
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16-Aug-2010
On 23 April 2010, the OECD Committee on Fiscal Affairs released for public comment a discussion draft on the application of Article 17 (Artistes and Sportsmen) of the Model Tax Convention. The OECD has now published the comments received on this consultation draft.
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22-Jul-2010
The OECD Council has today approved the 2010 Update to the Model Tax Convention. The contents of the update were previously released in draft form on 21 May and, after some final changes, were approved by the Committee on Fiscal Affairs on 22 June before being presented to the Council for final approval. A revised version of the condensed version of the OECD Model that will include the changes resulting from the update will be published in September.
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31-May-2010
The OECD Committee on Fiscal Affairs has released a Report which contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with the question of the extent to which either collective investment vehicles (CIVs) or their investors are entitled to treaty benefits on income received by the CIVs. These changes are expected to be included in the 2010 Update to the Model Tax Convention (the draft contents of which were released on 21 May 2010).
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21-May-2010
The OECD Committee on Fiscal Affairs has just released the draft contents of the next update to the OECD Model Tax Convention (the 2010 Update) prepared by Working Party 1 of the Committee. The update will be submitted for approval of the Committee in June and the OECD Council in July. As all the substantive contents of the 2010 Update have previously been released for comments through various discussion drafts, this draft is released for information only and not for additional comments.
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23-Apr-2010
From 23 April to 31 July 2010
The OECD Committee on Fiscal Affairs invites public comments on draft changes to the Commentary on Article 17 of the OECD Model Tax Convention, which deals with cross-border income derived from the activities of entertainers and sportsmen. Comments on these proposed changes (which will not be included in the next update to the Model Tax Convention scheduled for approval in June 2010) should be sent before 31 July 2010 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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10-Feb-2010
On 9 December 2009, the OECD Committee on Fiscal Affairs released for public comment a Public Discussion Draft of a Report which contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with the question of the extent to which either collective investment vehicles (CIVs) or their investors are entitled to treaty benefits on income received by the CIVs. The OECD has now published the comments received on this consultation draft.
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10-Feb-2010
On 25 November 2009, the OECD Committee on Fiscal Affairs released for public comments a draft Report which contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with tax treaty issues related to common telecommunication transactions. The OECD has now published the comments received on this consultation draft.
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10-Feb-2010
On 25 November 2009, the OECD Committee on Fiscal Affairs released for public comments a draft Report which contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with the application of tax treaties to state-owned entities, including Sovereign Wealth Funds. The OECD has now published the comments received on this consultation draft.
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08-Feb-2010
The OECD has released for public comment draft documentation for implementing a streamlined procedure for portfolio investors to claim reductions in withholding rates pursuant to tax treaties or domestic law in the source country. The draft documentation was developed to provide standardised documentation that could be used by countries that wish to adopt the “best practices” described in a report released by the OECD for public comment on 12 January 2009. Interested parties are invited to submit their comments on the draft documentation by 31 August 2010.
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28-Jan-2010
On 24 November 2009, the OECD Committee on Fiscal Affairs released for public comment a proposed draft of the new Article 7 of the Model Tax Convention. The OECD has now published the comments received on this consultation draft.
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09-Dec-2009
From 9 December 2009 to 31 January 2010
The OECD Committee on Fiscal Affairs has released as a discussion draft a Report which contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with the question of the extent to which either collective investment vehicles (CIVs) or their investors are entitled to treaty benefits on income received by the CIVs. Comments should be sent before 31 January 2010 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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25-Nov-2009
from 25-Nov-2009 to 31-Jan-2010
The OECD Committee on Fiscal Affairs invites public comments on draft changes to the Commentary on the OECD Model Tax Convention dealing with the application of tax treaties to state-owned entities, including Sovereign Wealth Funds. The Committee is considering the inclusion of these changes in the next update to the OECD Model Tax Convention, which is tentatively scheduled for the second part of 2010. Comments should be sent before 31 January 2010) to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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25-Nov-2009
from 25-Nov-2009 to 31-Jan-2010
The OECD Committee on Fiscal Affairs invites public comments on draft changes to the Commentary on the OECD Model Tax Convention dealing with tax treaty issues related to common telecommunication transactions. The Committee is considering the inclusion of these changes in the next update to the OECD Model Tax Convention, which is tentatively scheduled for the second part of 2010. Comments should be sent before 31 January 2010) to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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25-Nov-2009
24-Nov-2009 to 21-Jan-2010
On 24 November 2009, the OECD Committee on Fiscal Affairs approved the release, for public comment, of a revised draft of a new Article 7 (Business Profits) of the OECD Model Tax Convention and of related Commentary changes. The new Article 7 is aimed at ensuring the full application of the Report on Attribution of Profits to Permanent Establishments that the OECD adopted in 2008. Comments on the revised draft should be sent before 21 January 2010 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).
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25-Sep-2009
Two key objectives of the OECD work on the mutual agreement procedure (MAP) under tax treaties were to improve the timeliness of processing and completing MAP cases and to enhance the transparency of the MAP process. To those ends, the OECD has decided to make available to the public, via its website, annual statistics on the MAP caseloads of member countries and of non-OECD economies that agree to provide such statistics.
MAP statistics have now been provided for 2006 and 2007. Statistics for subsequent reporting periods will be posted on the OECD website as they become available.
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22-Sep-2009
On 21-22 September 2009, the OECD held a major conference “Transfer Pricing and Treaties in a Changing World”. Almost 700 transfer pricing and treaty experts from over 90 governments (OECD and non-OECD), the private sector, NGOs, academia and international organisations gathered in Paris for the event. In his opening address, Jeffrey Owens, Director of the OECD Centre for Tax Policy and Administration, stressed the significance of transfer pricing for OECD as well as non-OECD economies.
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08-Jun-2009
The Informal Consultative Group on the Taxation of Collective Investment Vehicles and Procedures for Tax Relief for Cross-Border Investors (ICG) prepared for the consideration of the OECD’s Committee on Fiscal Affairs (CFA) two reports which were released on 12 January 2009. Given the recommendations included in the reports, the CFA decided at the time of their release to invite comments from all interested parties before further consideration of the reports. The OECD has now published the comments received on the reports.
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26-Jan-2009
On 7 July 2008, the OECD Committee on Fiscal Affairs called for comments on a draft new Article 7 of the OECD Model Tax Convention and related Commentary changes. The OECD has now published the comments received on that draft.
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12-Jan-2009
The OECD has released two reports submitted to its Committee on Fiscal Affairs by an Informal Consultative Group of business and government representatives. The Reports address, respectively, technical issues relating to granting treaty benefits with respect to income of collective investment vehicles and procedural barriers to claims for treaty benefits that affect portfolio investors more generally. Interested parties are invited to send their comments before 6 March 2009.
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23-Sep-2008
On the occasion of the 8-9 September 2008 OECD Conference marking the 50th Anniversary of the OECD Model Tax Convention, Peter A. Barnes, Tax Counsel - International with General Electric Company of Fairfield, Connecticut in the United States, explained the great importance of the Model from the perspective of international business. His article appears in the OECD Observer.
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18-Jul-2008
On 17 July 2008, the OECD Council approved the contents of the 2008 Update to the OECD Model Tax Convention. The update had previously been released as a public discussion draft in April 2008. It was subsequently finalised and approved by the Committee on Fiscal Affairs on 25 June, when the Committee also approved a detailed response to the comments that had been sent on the discussion draft.
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18-Jul-2008
On 17 July 2008, the OECD Council approved the release of the 2008 Report on the Attribution of Profits to Permanent Establishments. An interim version of Parts I-III of the Report had previously been released in December 2006, and a discussion draft version of Part IV was released in August 2007. The Report was subsequently finalised and approved by the Committee on Fiscal Affairs on 24 June 2008.
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