Electronic Edition

*New Edition Coming September 2008 More>>

Updated to July 2005, Published October 2005

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This electronic version of the Model Tax Convention (eMTC) is based on the text as it was updated on July 2005, but includes some related elements not included in the loose-leaf version including the texts of the 1963 and 1977 Conventions. The electronic version also includes numerous features that will make working with the convention much easier.

Because the eMTC includes software that enables users to append notes to segments of Convention text; to navigate between Articles, Commentaries, History, and Country Positions; and to rapidly search the full text for terms and phrases, it is sold on a subscription basis as a downloadable, executable file on a one-year basis and the program reminds users to renew towards the end of the subscription period. For multi-user access that includes a SourceOECD/Taxation subscription, renewal notices are sent.

The electronic version of MTC includes the following powerful features:

R1. Transfer pricing, corresponding adjustments and the mutual agreement procedure
R2. The taxation of income derived from the leasing of industrial, commercial or scientific equipment
R3. The taxation of income derived from the leasing of containers
R4. Thin capitalisation
R5. Double taxation conventions and the use of base companies
R6. Double taxation conventions and the use of conduit companies R7. The taxation of income derived from entertainment, artistic and sporting activities
R8. Tax treaty override
R9. The 183 day rule: some problems of application and interpretation
R10. The tax treatment of software
R11. Triangular cases
R12. The tax treatment of employee's contributions to foreign pension schemes
R13. Attribution of income to permanent establishments
R14. Tax sparing
R15. The application of the OECD model tax convention to partnerships
R16. Issues related to article 14 of the model tax convention
R17. Restricting the entitlement to treaty benefits
R18. Treaty characterisation issues arising from e-commerce
R19. Issues arising under article 5 (permanent establishment) of the model tax convention
R20. Cross border income tax issues arising from employee stock option plans

The eMTC also includes the Recommendation of the OECD Council related to the MTC and the texts of the 1963 and 1977 model conventions. There is also a table listing, for each OECD country, countries with whom it has concluded bilateral conventions based on the MTC.

This new tool will also be available in French soon.

Screenshots USING eMTC

When purchasing the electronic version of the Model Tax Convention users are instructed where to go to download the file and are given a key code to access the publication. When executing the file, the user is asked for the key and when the key is entered, the program installs. At the end of the subscription period, the program can be opened but the text cannot be accessed. When the subscription renewal is paid, a new key code is provided to the user enabling opening of the program during the new period. When the Convention is updated, subscribers are informed and if their subscription is up to date, the update can be downloaded free of charge. When the update is installed, notes from the previous version are automatically brought into the new version.

When opening eMTC, the follow screen appears:

Model Tax Convention - eMTC

The Table of Contents appears on the left column and can be expanded or pruned as the user desires. At all times the Table of Contents will stay synchronized with text of the publication so the user can never get lost. The user instructions appear in the "Navigation Quick Start" box, which can be moved around the screen or minimized.

If the program is closed, clicking on the drag-on icon will open the program. If the program is open, Dragging a term or phrase onto the icon will result in a full-text search of the Convention for the desired term or phrase. The drag-on icon can be turned on or off and its size can be adjusted.

Scroll the Title Page for the copyright notice and a more detailed Table of Contents

The icons across the top of the screen allow for returning to the home Table of Contents, Backtracking, Pruning the Table of Contents, various Search functions, appending/moving/deleting of personal notes, cutting/copying/pasting, printing, and adjusting the text size on the screen. Click on "Help" for more detailed usage instructions.

When you open an article, you see the following:

Model Tax Convention - eMTC

Notice that when in an article, links are provided to the related commentary and history. Links are also available for footnotes.

When you open a commentary, you see:

Model Tax Convention - eMTC

Notice that from a commentary, you can link back to the text of the article in question and to related articles and reports. Text highlighted in blue is text as it appeared in a previous version of the Convention. Similar navigation and text identification appears in the country positions pages.

eMTC is sold on subscription as a downloadable, executable file, Subscriptions are sold on a one-year basis for a single user. If you are with a organization that wishes to use multiple copies of the OECD Model Tax Convention: Electronic Version please contact us as there are a number of options for access. There is also a table listing, for each OECD country, countries with whom it has concluded bilateral conventions based on the MTC.

eMTC is sold on an annual subscription as a downloadable, executable file. After you have purchased the subscription and the order has been processed by the OECD, you will be sent an email from ecompress@ecompress.com with instructions on how to download your subscription on to your computer’s hard drive. Before you purchase this subscription, you may wish to ensure that are able to download and open executable files on your computer system. You may be required to temporarily disable any anti-virus program on your PC during downloading and installation of this publication. Subscribers will be notified when future updates are avaialable for downloading during their subscription period. Subscribers will also receive a print copy of any condensed version of the Model Tax Convention that comes out during their subscription period.

Toby Green of OECD on eComPress:

"...the length and content of the MTC made PDF a poor solution...eMTC is a 3D product with commentary and history attached to each paragraph of the Convention. We needed a sophisticated solution that would enable users to navigate between the different types of content very quickly; users can now link from an article to its commentary instantly. The advanced annotation facility in eComPress allows tax professionals using eMTC to attach personal notes to specific areas of text, without jeopardizing the integrity of the actual publication." see press release

For more information about the electronic platform used in eMTC visit EIS

Order copies of the Electronic Edition »

Latest Update

Watch for information on the updating of the electronic version.

 

Note: If you would like to discuss any of the features, content, pricing, support and publishing schedule for the OECD Model Tax Convention, please contact us at info@itinet.org

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