Model tax convention on income and on capital: volume I and II, (updated 21 November 2017) (Model Tax Convention on Income and on Capital (Full Version))

Description

This publication is 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. Foreword Acknowledgement Table of contents Volume I Introduction A. Historical background B. Influence of the OECD Model Convention C. Tax policy considerations that are relevant to the decisionof whether to enter into a tax treaty or amend an existingtreaty D. Presentation of the Model Convention Model Convention with Respect to Taxes on Income and on Capital Summary of the convention Title and Preamble Chapter I. Scope of the convention Article 1. Persons covered Article 2. Taxes covered Chapter II. Definitions Article 3. General definitions Article 4. Resident Article 5. Permanent establishment Chapter III. Taxation of income Article 6. Income from immovable property Article 7. Business profits Article 8. International shipping and air transport Article 9. Associated enterprises Article 10. Dividends Article 11. Interest Article 12. Royalties Article 13. Capital gains Article 14. Independent Personal Services [Deleted] Article 15. Income from employment Article 16. Directors’ fees Article 17. Entertainers and sportspersons Article 18. Pensions Article 19. Government service Article 20. Students Article 21. Other income Chapter IV. Taxation of capital Article 22. Capital Chapter V. Methods for elimination of double taxation Article 23 A. Exemption method Article 23 B. Credit method Chapter VI. Special provisions Article 24. Non-discrimination Article 25. Mutual agreement procedure Article 26. Exchange of information Article 27. Assistance in the collection of taxes Article 28. Members of diplomatic missions and consular posts Article 29. Entitlement to benefits Article 30. Territorial extension Chapter VII. Final provisions Article 31. Entry into force Article 32. Termination Commentaries on the Articles of the Model Tax Convention Commentary on Article 1 Commentary on Article 2 Commentary on Article 3 Commentary on Article 4 Commentary on Article 5 Commentary on Article 6 Commentary on Article 7 Commentary on Article 8 Commentary on Article 9 Commentary on Article 10 Commentary on Article 11 Commentary on Article 12 Commentary on Article 13 Commentary on Article 14 [Deleted] Commentary on Article 15 Commentary on Article 16 Commentary on Article 17 Commentary on Article 18 Commentary on Article 19 Commentary on Article 20 Commentary on Article 21 Commentary on Article 22 Commentary on Articles 23 A and 23 B Commentary on Article 24 Commentary on Article 25 Commentary on Article 26 Commentary on Article 27 Commentary on Article 28 Commentary on Article 29 Commentary on Article 30 Commentary on Articles 31 and 32 non-OECD economies' Positions on the OECD Model Tax Convention Introduction Positions on Article 1 and its commentary Positions on Article 2 and its commentary Positions on Article 3 and its commentary Positions on Article 4 and its commentary Positions on Article 5 and its commentary Positions on Article 6 and its commentary Positions on Article 7 and its commentary Positions on Article 8 and its commentary Positions on Article 9 and its commentary Positions on Article 10 and its commentary Positions on Article 11 and its commentary Positions on Article 12 and its commentary Positions on Article 13 and its commentary Positions on Article 14 and its commentary [Deleted] Positions on Article 15 and its commentary Positions on Article 16 and its commentary Positions on Article 17 and its commentary Positions on Article 18 and its commentary Positions on Article 19 and its commentary Positions on Article 20 and its commentary Positions on Article 21 and its commentary Positions on Article 22 and its commentary Positions on Articles 23 A and 23 B and its commentary Positions on Article 24 and its commentary Positions on Article 25 and its commentary Positions on Article 26 and its commentary Positions on Article 28 and its commentary Positions on Article 29 and its commentary Positions on Article 30 and its commentary Volume II Table of contents Previous reports related to the Model Tax Convention Transfer Pricing, Corresponding Adjustments and the Mutual Agreement Procedure The Taxation of Income Derived from the Leasing of Industrial, Commercial or Scientific Equipment The Taxation of Income Derived from the Leasing of Containers Thin Capitalisation Double Taxation Conventionsand the Use of Base Companies Double Taxation Conventionsand the Use of Conduit Companies The Taxation of Income Derivedfrom Entertainment, Artistic and Sporting Activities Tax Treaty Override The 183 Day Rule: Some Problems of Application and Interpretation The Tax Treatment of Software Triangular Cases The Tax Treatmentof Employees’ Contributions to Foreign Pension Schemes Attribution of Income to Permanent Establishments Tax Sparing: a Reconsideration The Application of the OECD Model Tax Convention to Partnerships Issues Related to Article 14 of the OECD Model Tax Convention Restricting the Entitlement to Treaty Benefits Treaty Characterisation Issues Arising from E-Commerce Issues Arising under Article 5 (Permanent Establishment) of the Model Tax Convention Cross-border Income Tax Issues Arising from Employee Stock-Option Plans Improving the Resolution of Tax Treaty Disputes Application and Interpretation of Article 24 (Non-Discrimination) Tax Treaty Issues Related to REITs The Granting of Treaty Benefits with respect to the Income of Collective Investment Vehicles Tax Treaty Issues Related to Emissions Permits/Credits Issues Related to Article 17 of the OECD Model Tax Convention Appendix. Recommendation of the OECD Council concerning the Model Tax Convention on income and on capital