This Condensed Version of the OECD Model Tax Convention contains the articles and commentaries of the Model Tax Convention as it read on 17 July (OECD Approves the Update to the OECD Model Tax Convention, THE UPDATE TO THE MODEL TAX CONVENTION, OECD (July 22, day a report on this subject, updating a version of the report to take. (OECD Approves the Update to the OECD Model Tax Convention, THE UPDATE TO THE MODEL TAX CONVENTION, OECD (July 22, day a report on this subject, updating a version of the report to take.
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Revised Commentary on Article 7. The revised Commentary on Article 7 was first released as a public discussion draft on 10 April The primary purpose of tax treaties is to eliminate double taxation as an obstacle to international trade and investment; thereby, promoting the development of economic relations oecd model tax convention 2008 countries.
Though every tax treaty is subject to negotiations between the two Contracting States, the majority of tax treaties are fairly similar. Importantly, the use of the OECD Model Convention may significantly reduce the costs and accelerate the negotiation process.
oecd model tax convention 2008 It should, however, be noted that the OECD Model Convention is not legally binding; rather, a point of reference typically relied upon to achieve, inter alia, the abovementioned objectives. The fundamental principle underlying the entire OECD Model Convention is that the allocation of taxing rights stems from the substantive economic nexus of the income and capital.
However, it at times does provide leeway to Contracting States.
Model Tax Convention on Income and on Capital: Condensed Version - OECD - Google книги
Indeed, while Contracting States will usually incorporate the substantive principles of the Model into their treaties, a certain flexibility remains; for example, with respect to reduced rates oecd model tax convention 2008 withholding tax and by which method double taxation is avoided.
These do not constitute disagreement with the text of the Model; rather they assist in understanding how that state will apply the provisions of a given Article.
Importantly, however, a good understanding of the OECD Model Convention itself will not suffice for a sound analysis of cross-border transactions.
The situation of dual-resident persons who are treaty non-residents under the tie-breaker rule.
The OECD approves the Update to the Model Tax Convention - OECD
Certain aspects of the definition of royalties. An interpretation issue related to the distribution of software.
Whether days of residence should be taken into account for the purposes of the oecd model tax convention 2008 of the day rule of subparagraph 2a of Article A minor drafting change to paragraph A minor updating of paragraph 12 of the Commentary on Article