UK and International Tax news

OECD Publishes Latest Version Of The Model Tax Convention On Income And On Capital

Friday 26th April 2019

The OECD has published the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital.

This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, the Recommendation of the OECD Council, the historical notes and the background reports.

The full version of the OECD Model Tax Convention is published regularly to reflect updates.

International juridical double taxation is generally defined as the imposition of comparable taxes in two or more states on the same taxpayer in respect of the same subject matter and for identical periods and has harmful effects on the international exchange of goods and services and cross-border movements of capital, technology and persons.

In recognition of the need to remove this obstacle to the development of economic relations between countries, as well as of the importance of clarifying and standardising the fiscal situation of taxpayers who are engaged in activities in other countries, the OECD MTC on Income and on Capital provides a means to settle on a uniform basis the most common problems that arise in the field of international juridical double taxation.

The OECD MTC requires constant review to address the new tax issues that arise in connection with the evolution of the global economy. Working Party No. 1 of the OECD’s Committee on Fiscal Affairs meets this need and its work results in regular changes to the Model. Updates were published in 1994, 1995, 1997, 2000, 2003, 2005, 2008, 2010, 2014 and 2017.

Beginning with the 1997 update, the Model was presented in two volumes. Volume I includes the Introduction and the text of the Articles of the Model and their Commentaries. Volume II includes a section on the positions of non-member countries, reprints of previous reports dealing with tax conventions that the Committee on Fiscal Affairs has adopted since 1977, and the text of the Council Recommendation on the Model Tax Convention.

A condensed version of the 2017 Model, which includes only the Introduction, the text of the Articles of the Model, their Commentaries and the positions of non-member countries is also available from the OECD website and library.


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