International Tax

Documents

OECD Model Tax Convention 2014
List of OECD Member Countries, and of Non-member Countries that have published
their position regarding the OECD Model Tax Convention and Commentary
Recommendation (1997) of the OECD Council concerning the Model Tax Convention
on Income and on Capital
Text (2014) of the OECD Model Convention on Income and Capital
Expert explanation of the integrated texts of the OECD ‘Introduction’ and ‘Commentary’
OECD ‘Introduction’ to OECD Model Tax Convention and Commentary 1977 and 1992-2014
OECD ‘Introduction’ to the Positions of Non-member Countries
OECD Commentary on the Model Conventions of 1977 and 1992 (incorporating the changes of
1994, 1995, 1997, 2000, 2003, 2005, 2008, 2010 and 2014)
OECD Draft Convention and Commentary and Recommendation
UN Model Double Taxation Convention 2011 (2001, 1980)
UN Commentary 2011
United States: Technical Explanation of the 2006 US Model Income Tax Convention
Intra-ASEAN Model Double Taxation Convention (1987)
OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts (1982)

OECD Transfer pricing guidelines for multinational enterprises and tax administrations
(1995-2013)
OECD Report: The attribution of profits to permanent establishments (2010)
1690 OECD Report: The application of the OECD Model Tax Convention to partnerships (1999)
The Granting of treaty benefits with respect to the income of collective investment vehicles
(April 2010)
OECD Report on Harmful Tax Competition – An Emerging Global Issue (1998)
OECD Consolidated Application Note – Guidance in applying the 1998 report to preferential
tax regimes (2004)
OECD Harmful Tax Project: 2004 Progress report
[Art. 10-12] Report OECD Informal Consultative Group – Possible improvements to procedures for
tax relief for cross-border investors (January 2009)
[Art. 10-12] Treaty relief and Compliance Enhancement (TRACE) – Implementation Package
approved by CFA (January 2013)
[Art. 25] OECD Draft Manual on effective mutual agreement procedures (MEMAP) (March 2006)
(table of contents)
[Art. 26] OECD Manual on the implementation of exchange of information provisions for tax
purposes, approved by the OECD Committee on Fiscal Affairs on 23 January 2006
[Art. 26] Keeping It Safe: The OECD guide on the protection of confidentiality of information
exchanged for tax purposes (July 2012)
[Art. 26] Automatic Exchange of Information: What it is, how it works, benefits, what remains to
be done (July 2012)

OECD Discussion draft on Art. 1 (Persons covered): The granting of treaty benefits with respect to the income of collective investment vehicles (December 2009)
OECD Discussion draft on Art. 5 (Permanent establishment) – Interpretation and application of Article 5 (Permanent establishment) of the OECD Model Tax Convention (October 2012)
OECD Discussion draft on Art. 9 / TP Guidelines: Revised discussion draft on transfer pricing aspects of intangibles (July 2013)
OECD Discussion draft on Art. 10 (Dividends): Tax treaty issues related to REITs (October 2007)
OECD Discussion draft on Articles 10, 11 and 12: Revised proposals concerning the meaning of ‘beneficial owner’ in Articles 10, 11 and 12 of the OECD Model Tax Convention (October 2012)
OECD Discussion draft on Art. 17 (Artistes and sportsmen): Application of Article 17 (Artistes and sportsmen) of the OECD Model Tax Convention (April 2010)
OECD Discussion draft on Art. 18 (Pensions) Tax treaty treatment of termination payments (June 2013)
OECD Discussion draft on Art. 24 (Non-discrimination) Application and interpretation of Article 24 (Nondiscrimination) (May 2007)

Committee of Fiscal Affairs: Clarification on the application of the permanent establishment
definition in e-commerce – [Proposed] Changes to the Commentary on the Model Tax
Convention on Article 5 (22 December 2000)
Technical Advisory Group discussion paper: Attribution of profit to a permanent establishment
involved in electronic commerce transactions (February 2001)
Technical Advisory Group report to the OECD CFA WP No. 1: Tax treaty characterisation issues
arising from e-commerce (November 2002)
Technical Advisory Group discussion paper: Are the current Treaty rules for taxing business profits
appropriate for e-commerce? (November 2003)
E-commerce: Transfer Pricing and Business Profits Taxation (May 2005)

This part includes:

Vienna Convention on the law of treaties: Text excerpts, Commentary ad the Official explanation of Articles 31, 32 and 33
General Agreement on Tariffs and Trade (excerpt)
Convention for the Protection of Human Rights and Fundamental Freedoms

EU Directive 2011/16/EU on administrative cooperation in the field of taxation, as amended in 2014
Council of Europe / OECD 1988 Convention on Mutual Administrative Assistance in Tax Matters, as
amended by 2010 Protocol
OECD (Model) Agreement on Exchange of Information on Tax Matters (2002)
OECD Automatic exchange of information (2014)
Declaration OECD Council – 6 May 2014
Standard for automatic exchange of financial information – Common reporting standard –
13 February & 15 July 2014