Model Tax Convention on Income and on Capital 2025 (Full Version)

This publication is the 11th edition of the full version of the Model Tax Convention on Income and on Capital, a key reference used by OECD Members and non-Members as a basis for negotiating, applying and interpreting bilateral tax treaties. It plays a central role in removing tax-related barriers to cross border trade and investment, helping to prevent tax evasion and avoidance, and addressing issues of international double taxation. This edition contains the full text of the Model Tax Convention as it read on 18 November 2025, including the Articles, Commentaries, non-Member economies’ positions, the Recommendation of the OECD Council, as well as the historical notes and background reports. The Model Tax Convention is updated regularly to reflect developments in international taxation.