18/12/2017 – The latest edition of the OECD Model Tax Convention has been released today, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS).
The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions, plays a crucial role in removing tax related barriers to cross border trade and investment. It is the basis for negotiation and application of bilateral tax treaties between countries, designed to assist business while helping to prevent tax evasion and avoidance. The OECD Model also provides a means for settling on a uniform basis the most common problems that arise in the field of international double taxation.
The 2017 edition of the OECD Model mainly reflects a consolidation of the treaty-related measures resulting from the work on the OECD/G20 BEPS Project under Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements), Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances), Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status) and Action 14 (Making Dispute Resolution More Effective).
When the OECD published its first Draft Model Tax Convention in 1963, only a few dozen tax agreements were in force. Since that time, the OECD Model Tax Convention has facilitated bilateral negotiations between countries and made possible a desirable harmonisation between bilateral conventions for the benefit of both taxpayers and national administrations. More than 3000 tax treaties in force around the world are based on the OECD Model, which is regularly updated. The full version of the OECD Model Tax Convention, including the Articles, Commentaries, non-member economies’ positions, and historical notes, will be published in the coming year.
For more information please contact Pascal Saint-Amans (+33 1 45 24 91 08), Director of the OECD’s Centre for Tax Policy and Administration (CTPA), or Jefferson VanderWolk (+33 1 45 24 94 90), Head of CTPA’s Tax Treaty, Transfer Pricing & Financial Transactions Division.