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International Tax Materials

A. Model Tax Treaties, etc.
OECD Model Tax Convention 2010

  • List of OECD Member Countries, and of Non-member Countries that have published
    their position regarding the OECD Model Tax Convention and Commentary
  • Recommendation (1997) of the OECD Council concerning the Model Tax Convention
    on Income and on Capital
  • Text (2010) of the OECD Model Convention on Income and Capital
  • Editorial explanation of the integrated texts of the OECD ‘Introduction’ and ‘Commentary’
  • OECD ‘Introduction’ to OECD Model Tax Convention and Commentary 1977 and 1992-2010
  • OECD ‘Introduction’ to the Positions of Non-member Countries
  • OECD Commentary on the Model Conventions of 1977 and 1992 (incorporating the changes of
    1994, 1995, 1997, 2000, 2003, 2005, 2008 and 2010) THERE ARE LIKE 500 PAGES OF THIS
  • Comparison of various model income tax treaties: 2006 US Model Income Tax Convention, 2001
    UN Model Convention, 1963 OECD Draft Convention and 1977 & 1992-2010 OECD Model Tax
    Conventions
  • 1963 OECD Draft Convention and Commentary
  • United Nations Model Double Taxation Convention 2001-1980
  • United States: Technical Explanation of the 2006 US Model Income Tax Convention
  • Intra-ASEAN Model Double Taxation Convention (1987)
  • [Draft] Convention between the Kingdom of the Netherlands and … for the avoidance of double
    taxation and the prevention of fiscal evasion with respect to taxes on income and on capital
    (1986)
  •  OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts (1982)

B. OECD Reports and Guidelines

  • OECD Transfer pricing guidelines for multinational enterprises and tax administrations
    (1995-1999)
  • OECD Report: The attribution of profits to permanent establishments – Parts I–IV (July 2008)
  • OECD Report: The application of the OECD Model Tax Convention to partnerships (1999)
  • OECD Draft Manual on effective mutual agreement procedures (MEMAP) (March 2006) (table of
    contents) (OECD Manual on the implementation of exchange of information provisions for tax purposes,
    approved by the OECD Committee on Fiscal Affairs on 23 January 2006 (table of contents)
  • Report OECD Informal Consultative Group – Possible improvements to procedures for tax relief for
    cross-border investors (January 2009)
  • Report OECD Informal Consultative Group – Granting of treaty benefits with respect to the income
    of collective investment vehicles (January 2009)
  • OECD Report on Harmful Tax Competition – An Emerging Global Issue (1998)
  • OECD Consolidated application note – Guidance in applying the 1998 report to preferential tax
    regimes (2004)
  • OECD Harmful Tax Project: 2004 Progress report

C. OECD Discussion drafts

  • on Art. 1 (Persons covered): The granting of treaty benefits with respect to the income of
    collective investment vehicles (December 2009)
  • on Art. 1 (Persons covered): Possible improvements to procedures for tax relief for cross-border
    investors: implementation package (February 2010)
  • on Art. 1 (Persons covered) Application of tax treaties to state-owned entities, including
    sovereign wealth tax funds (November 2009)
  • on Art. 5 (Definition Permanent Establishment): Tax treaty issues related to common
    telecommunication transactions (November 2009)
  • on Art. 7 (Business profits): Revised draft of the new Article 7 of the OECD Model Tax Convention
    and related Commentary changes (November 2009)
  • on Art. 7 (Business profits) and Article 9 (Associated enterprises): Transfer pricing aspects of
    business restructurings (September 2008)
  • on Art. 10 (Dividends): Tax treaty issues related to REITs (October 2007)
  • on Art. 17 (Artistes and sportsmen): Application of Article 17 (Artistes and sportsmen) of the
    OECD Model Tax Convention (April 2010)
  • on Art. 24 (Non-discrimination) Application and interpretation of Article 24 (Nondiscrimination)
    (May 2007)

D. OECD Reports on e-commerce

  • Committee of Fiscal Affairs: Clarification on the application of the permanent establishment
    definition in e-commerce – [Proposed] Changes to the Commentary on the Model Tax
    Convention on Article 5 (22 December 2000) (table of contents)
  • Technical Advisory Group discussion paper: Attribution of profit to a permanent establishment
    involved in electronic commerce transactions (February 2001) (table of contents)
  • Technical Advisory Group report to the OECD CFA WP No. 1: Tax treaty characterisation issues
    arising from e-commerce (November 2002) (table of contents)
  • Technical Advisory Group discussion paper: Are the current Treaty rules for taxing business profits
    appropriate for e-commerce? (November 2003) (table of contents)
  • E-commerce: Transfer Pricing and Business Profits Taxation (May 2005)

E. Treaty law
Vienna Convention on the law of treaties

  • Text (excerpt)
  • Official explanation of Articles 31, 32 and 33
  • General Agreement on Tariffs and Trade (excerpt)
  • Convention for the Protection of Human Rights and Fundamental Freedoms

 

F. Exchange of information & other administrative assistance

  • EC Directive of 19 December 1977
  • Council of Europe / OECD 1988 Convention on Mutual Administrative Assistance in Tax Matters,
    with 2010 Protocol
  • Text
  • Explanatory Report
  • OECD (Model) Agreement on Exchange of Information on Tax Matters (2002)
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