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)) [10th ed., (full version)] 9264303782, 9789264303782

Table of contents :
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

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