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Now those who place a subscription to the Electronic edition with ITI will also receive a complimentary copy of the updated paperback "OECD Model Tax Convention- Condensed Edition - July 2005" to carry in the briefcase. That's a small $124 investment with a $66 bonus value included.
Content Description | Features of Electronic Version | Using eMTC
CONTENT
The OECD Model Tax Convention on Income and on Capital (MTC) serves as a model used by countries when negotiating bilateral tax agreements. These agreements are entered into by countries to clarify the situation when a taxpayer might find himself subject to taxation in more than one country. The Model Tax Convention is dynamic in that it is constantly monitored and updated as economies evolve and new tax questions arise. In recent years, for example, special reports have had to be done on tax treatment of software and treaty characterization issues arising from e-commerce.
The Model Tax Convention consists of Articles, Commentaries on the Articles which include OECD member country Reservations, Histories of the Articles, Non-Member Country Positions on the Articles, and Special Reports related to the Convention. This model is used not only by country officials negotiating bilateral tax treaties, but also by lawyers and accountants having to interpret these treaties for their clients.
FEATURES OF THE ELECTRONIC VERSION
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:
- Users can append their own notes to specific paragraphs in the text of the Model Tax Convention. Users can exchange their notes with other users. All notes are automatically transcribed in context into updated versions of the eMTC.
- Users can quickly do full-text searches for particular terms or phrases using the drag-on icon and the search tools. With every word, number, and alphanumeric indexed, users can search for absolutely everything within the publication.
- Users can easily navigate between Articles, Commentary, History, Country Positions, and Related Reports through the table of contents and extensive internal linking.
- Text from previous versions of the Model Tax Convention is highlighted in blue, to distinguish it from the current version. This is important in cases where the action in question took place at a time when a previous version of the Convention was in force.
- Users can cut and paste or 'drag and drop' from the text with all formatting remaining preserved.
- The program is highly compressed, so it does not take up much space on a hard drive.
- Users can print from the text.
In addition to the Articles, Commentaries, and Country Positions, the eMTC also includes the following related reports. When mentioned within commentaries to articles, links to these reports are provided.
- 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
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. |
