Tax Treaties

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 fo taxing income and capital.

What's new

OECD releases discussion draft on the application of tax treaties to state-owned entities, including Sovereign Wealth Funds

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).

OECD releases discussion draft on tax treaty issues related to common telecommunication transactions

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).

OECD releases revised discussion draft of a new Article 7 (Business Profits) of its Model Tax Convention

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).

Dispute Resolution: Country Mutual Agreement Procedure Statistics Released

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.

OECD holds a major Conference “Transfer Pricing and Treaties in a Changing World”

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.

Public comments on Reports Relating to Claims for Treaty Benefits by Portfolio Investors

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.

Public comments on draft new Article 7 (Business Profits) of the OECD Model Tax Convention and related Commentary changes

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.

 

OECD Releases Reports relating to Claims for Treaty Benefits by Portfolio Investors

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.

Tax Executive Celebrates OECD Model Tax Convention

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.

Conference on the 50th Anniversary of the OECD Model Tax Convention, remarks by Angel Gurría

08-Sep-2008

In his remarks, Angel Gurría underlined that throughout these five decades, the OECD Model Tax Convention has established itself as the means of settling the most common problems that arise in the field of international taxation on a uniform basis.

The OECD approves the 2008 Update to the Model Tax Convention

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.

OECD releases final Report on the Attribution of Profits to Permanent Establishments

18-Jul-2008

On 17 July 2008, the OECD Council approved the release of the final 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.

OECD provides Update on Work on Treaty Relief for Collective Investment Vehicles and other Portfolio Investors

18-Jul-2008

An Informal Consultative Group of business and government representatives continues its work on improving procedures for claiming treaty benefits, while protecting the compliance interests of governments. This update reflects progress made in the past year on technical issues relating to granting treaty benefits with respect to income of collective investment vehicles, as well as procedural issues that affect portfolio investors more generally. The final report of the Group is expected to be presented to the Committee on Fiscal Affairs in January 2009.

Discussion draft on a new Article 7 (Business Profits) of the OECD Model Tax Convention

from 07-Jul-2008 to 31-Dec-2008

On 24 June 2008, the Committee on Fiscal Affairs approved the Report on Attribution of Profits to Permanent Establishments. It also approved the release, for public comment, of the second part of the implementation package for the conclusions of that Report, i.e. a new version of Article 7 and its Commentary. This new Article and related Commentary changes are now being released as a discussion draft for public comment. Comments should be sent before 31 December 2008 to Jeffrey Owens, Director, CTPA (jeffrey.owens@oecd.org).

Public comments on draft contents of the 2008 Update to the Model Tax Convention

09-Jun-2008

On 21 April 2008, the OECD Committee on Fiscal Affairs published the draft contents of the 2008 Update to the Model Tax Convention.  The OECD has now published the comments received on that draft.

 

Draft contents of the 2008 Update to the Model Tax Convention

21-Apr-2008

From 21 April to 31 May 2008
The OECD Committee on Fiscal Affairs has just released the draft contents of the 2008 update to the OECD Model Tax Convention, which will be finalized in June. The contents of the 2008 update result primarily from reports that have already been released for comments; the draft update also includes, however, a few other technical changes that have not previously been released (see Part I of the report) and on which comments are particularly invited.  Comments on the 2008 update to the Model Tax Convention should be sent to jeffrey.owens@oecd.org by 31 May 2008.

Joint OECD - IFA (India) Conference "At the Crossroads of Tax Co-operation" held in Mumbai, 23-25 January 2008

25-Jan-2008

More than 250 participants met in Mumbai, India, on 23-25 January 2008 to discuss a broad range of international tax issues at the Conference “At the Crossroads of Tax Co-operation:  IFA (India) – OECD” that was jointly organized by the Indian Branch of the International Fiscal Association (IFA) and the Organisation for Economic Co-operation and Development (OECD) to mark the accession of India as observer to the OECD Committee on Fiscal Affairs.

See more news and events… Top of page

Publication

Seventh edition of the condensed version of the OECD Model Tax Convention on Income and on Capital.

Model Tax Convention on Income and on Capital - Condensed Version (July 2008)