Model Tax Convention on Income and on Capital 2014 (Full Version) [electronic resource] /
Organisation for Economic Co-operation and Development.
Paris : OECD Publishing,
2015.
This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014, including the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back to 1963), the detailed list of conventions between OECD member countries and the background reports.
Foreword -- Introduction -- Title and Preamble -- Article 1 Persons covered -- Article 2 Taxes covered -- Article 3 General definitions -- Article 4 Resident -- Article 5 Permanent establishment -- Article 6 Income from immovable property -- Article 7 Business profits -- Article 8 Shipping, inland waterways transport and air transport -- Article 9 Associated enterprises -- Article 10 Dividends -- Article 11 Interest -- Article 12 Royalties -- Article 13 Capital gains -- Article 14 Concerning the Taxation of 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 -- Article 22 Capital -- Article 23 A and 23 B. Exemption method and Credit method -- 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 Territorial extension -- Article 30 Entry into force -- Article 31 Termination -- Commentary on Article 1: Concerning the Persons Covered by the Convention -- Commentary on Article 2: Concerning Taxes Covered by the Convention -- Commentary on Article 3: Concerning General Definitions -- Commentary on Article 4: Concerning the Definition of Resident -- Commentary on Article 5: Concerning the Definition of Permanent Establishment -- Commentary on Article 6: Concerning the Taxation of Income From Immovable Property -- Commentary on Article 7: Concerning the Taxation of Business Profits -- Commentary on Article 8: Concerning the Taxation of Profits From Shipping, Inlandwaterways Transport and Air Transport -- Commentary on Article 9: Concerning the Taxation of Associated Enterprises -- Commentary on Article 10: Concerning the Taxation of Dividends -- Commentary on Article 11: Concerning the Taxation of Interest -- Commentary on Article 12: Concerning the Taxation of Royalties -- Commentary on Article 13: Concerning the Taxation of Capital Gains -- Commentary on Article 14: Concerning the Taxation of Independent Personal Services -- Commentary on Article 15: Concerning the Taxation of Income From Employment -- Commentary on Article 16: Concerning the Taxation of Directors' Fees -- Commentary on Article 17: Concerning the Taxation of Entertainers and Sportspersons -- Commentary on Article 18: Concerning the Taxation of Pensions -- Commentary on Article 19: Concerning the Taxation of Remuneration in Respect of Government Service -- Commentary on Article 20: Concerning the Taxation of Students -- Commentary on Article 21: Concerning the Taxation of Other Income -- Commentary on Article 22: Concerning the Taxation of Capital -- Commentary on Article 23 A. and 23 B.: Concerning the Methods for Elimination of Double Taxation -- Commentary on Article 24: Concerning Non-Discrimination -- Commentary on Article 25: Concerning the Mutual Agreement Procedure -- Commentary on Article 26: Concerning the Exchange of Information -- Commentary on Article 27: Concerning the Assistance in the Collection of Taxes -- Commentary on Article 28: Concerning Members of Diplomatic Missions and Consular Posts -- Commentary on Article 29: Concerning the Territorial Extension of the Convention -- Commentary on Article 30 and 31: Concerning the Entry Into force and the Termination of the Convention -- Non-OECD Economies' Positions on the OECD Model Tax Convention: Introduction -- Positions on Article 1 (Persons Covered) and its commentary -- Positions on Article 2 (Taxes Covered) and its commentary -- Positions on Article 3 (General Definitions) and its commentary -- Positions on Article 4 (Resident) and its commentary -- Positions on Article 5 (Permanent Establishment) and its commentary -- Positions on Article 6 (Income from Immovable Property) and its commentary -- Positions on Article 7 (Business Profits) and its commentary -- Positions on Article 8 (Shipping, Inlandwaterways Transport and Air Transport) and its commentary -- Positions on Article 9 (Associated Enterprises) and its commentary -- Positions on Article 10 (Dividends) and its commentary -- Positions on Article 11 (Interest) and its commentary -- Positions on Article 12 (Royalties) and its commentary -- Positions on Article 13 (Capital Gains) and its commentary -- Positions on Article 14 (Independent Personal Services) and its commentary -- Positions on Article 15 (Income from Employment) and its commentary -- Positions on Article 16 (Directors' Fees) and its commentary -- Positions on Article 17 (Entertainers and Sportspersons) and its commentary -- Positions on Article 18 (Pensions) and its commentary -- Positions on Article 19 (Government Service) and its commentary -- Positions on Article 20 (Students) and its commentary -- Positions on Article 21 (Other Income) and its commentary -- Positions on Article 22 (Capital) and its commentary -- Positions on Article 23 A. and 23 B. (Exemption Method and Credit Method) and its commentary -- Positions on Article 24 (Non-Discrimination) and its commentary -- Positions on Article 25 (Mutual Agreement Procedure) and its commentary -- Positions on Article 26 (Exchange of Information) and its commentary -- Positions on Article 28 (Members of Diplomatic Missions and Consular Posts) and its commentary -- Positions on Article 29 (Territorial Extension) and its commentary -- R(1). Transfer pricing, corresponding adjustments and themutual agreement procedure -- R(2). The taxation of income derived from the leasingof industrial, commercial or scientific equipment -- R(3). The taxation of income derived from the leasing of containers -- R(4). Thin capitalisation -- R(5). Double taxation conventions and the use of base companies -- R(6). Double taxation conventions and the use of conduit companies -- R(7). The taxation of income derived from entertainment, artistic and sporting activities -- R(8). Tax treaty override -- R(9). The 183 day rule: some problems of application and interpretation -- R(10). The tax treatment of software -- R(11). Triangular cases -- R(12). The tax treatment of employees' contributions to foreign pension schemes -- R(13). Attribution of income to permanent establishments -- R(14). Tax sparing: a reconsideration -- R(15). The application of the OECD Model Tax Convention to partnerships -- R(16). Issues related to Article 14 of the Model Tax Convention -- R(17). Restricting the entitlement to treaty benefits -- R(18). Treaty characterisation issues arising from e-commerce -- R(19). Issues arising under Article 5 (permanent establishment) of the Model Tax Convention -- R(20). Cross-border income tax issues arising from employee stock-option plans -- R(21). Improving the resolution of tax treaty disputes -- R(22). Application and interpretation of Article 24 (non-discrimination) -- R(23). Tax treaty issues related to REITs -- R(24). The granting of treaty benefits with respect to the income of collective investment vehicles -- R(25). Tax Treaty Issues Related to Emissions Permits/Credits -- R(26). Issues Related to Article 17 of the OECD Model Tax Convention -- List of Tax Conventions on Income and on Capital Between OECD Member Countries -- Recommendation of the OECD Council Concerning the Model Tax Convention on Income and on Capital.
This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014, including the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back to 1963), the detailed list of conventions between OECD member countries and the background reports.
Taxation