Tag: Model tax convention

A model (or template) that can be used as the basis for an actual Tax Treaty negotiated between two countries. There are two primary Model Tax Conventions, one prepared by the UN, and one prepared by the OECD. The two Model Tax Conventions are largely the same, although they differ in a few significant specifics

OECD Model Tax Convention 2017

A new 2017 edition of the OECD Model Tax Convention has been released, 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). See the also the Commentary on article 9 concerning the taxation of associated enterprises, and Commentary on article 7 concerning the taxation of business profits. The New Model Tax Convention ...