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Model Tax Convention on
Income and on Capital: Condensed Version, July 2010 |
| The Model Tax Convention on Income and on Capital is
used by both OECD member countries, including Canada, and non-member countries
as the basis for the negotiation, application and interpretation of their
bilateral tax treaties. The Model and the worldwide network of over 3000
treaties based upon it provide a means of settling on a uniform basis the most
common problems that arise in the field of international double taxation. They
thus help to prevent those problems from operating as obstacles to the free
movement of goods, services, capital and persons between countries. |
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This publication is
the eighth edition of the condensed version of the OECD Model Tax Convention on
Income and on Capital. It contains the full text of the Articles, Commentary,
and Country Positions of the Model Tax Convention as read on July 22, 2010,
after the adoption of the eighth update by the Council of the OECD. The 2010
version includes a new Article 7 (Business Profits), which completes the
Committee's work on the attribution of profits to permanent establishments. It
also introduces new text relating to the granting of the benefits of tax
treaties with respect to the income of collective investment vehicles, the
application of tax treaties to State-owned entities (including sovereign wealth
funds), tax treaty issues relating to common telecommunications transactions,
and the application of Article 15 (Income from Employment) to employees who
work for a short duration in a foreign country.
This shorter version
contains the full text of the Model Tax Convention, but without the historical
notes, the detailed list of tax conventions between OECD member countries and
the background reports that are included in the loose-leaf version. |
Contents:
- Introduction
- Model Convention with respect to Taxes on Income
and on Capital
- Commentaries on the Articles of the Model Tax
Convention
- Non-OECD economies' positions on the OECD Model Tax
Convention
- Annex: Recommendations of the OECD Council
concerning the Model Tax Convention on Income and on Capital
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