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Celebrating the 50th Anniversary of the Model Tax Convention and incorporating the latest updates to the Model we are pleased to announce the pending publication of the OECD's Model Tax Convention on Income and on Capital: Condensed Version.
We are expecting the new edition to be available at the end of August 2008.
To reserve your copy(ies) of the new edition please enter the quantity required on this page and proceed to the checkout.
Price: $92.00
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The OECD Model Tax Convention is periodically updated to take account of new developments and to reflect the experience gained by countries in the application of tax conventions.
The 2008 Model Tax Convention incorporates the latest changes to the Model which were approved by the OECD Council. These changes were released in draft form for comments early in 2008.
The contents of the 2008 update result primarily from the following reports, which were all previously released for comments:
“Improving the Resolution of Tax Treaty Disputes”. That report was adopted by the Committee on Fiscal Affairs on 30 January 2007 and made public on 7 February 2007.
“Revised Commentary on Article 7”. The revised Commentary on Article 7 that is included in this update was released as a public discussion draft on 10 April 2007.
“Application and Interpretation of Article 24 (Non-Discrimination)”. That report was released as a public discussion draft on 3 May 2007.
“Tax Treaty Issues related to REITs”. That report was released as a public discussion draft on 31 October 2007.
“The Tax Treaty Treatment of Services: Proposed Commentary Changes”. That report was released as a public discussion draft on 8 December 2006.
The update does not include, however, the revised draft changes to the Commentary on paragraph 2 of Article 15 that were publicly released for comments on 12 March 2007 .
Although these changes had already been revised following their initial release in April 2004, the Working Party has concluded that further discussions of these changes were necessary.
The update also includes a number of technical changes to the Commentary on the Model Tax Convention that have not been previously released for comments. These changes deal with the following topics:
The concept of “place of effective management”
The situation of dual-resident persons who are treaty non-residents under the tie-breaker rule.
Certain aspects of the definition of royalties.
An interpretation issue related to the distribution of software.
Whether days of residence should be taken into account for the purposes of the computation of the 183-day rule of subparagraph 2a) of Article 15.
A minor drafting change to paragraph 32.6 of the
Commentary on Articles 23 A and 23 B.
A minor updating of paragraph 12 of the Commentary on Article 21.
As part of the update, a number of changes and additions will also be made to the observations, reservations and positions of member and non-member countries. These changes and additions are in the process of being formulated and will be included in the final version of the update.
VIEW DRAFT UPDATE
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