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One of the suggestions put forward by BEPS Action 7 to mitigate this is expanding the dependent agent The Convention is the latest in an ongoing series of releases related to the OECD/G20 Project addressing Base Erosion and Profit Shifting (the “BEPS Project”), which is a major and continuing effort described as “aiming to realign taxation with economic substance and value creation, while preventing double taxation.” The Multilateral Convention and BEPS 3 Glossary Abbreviation Terminology ALP Arm’s Length Price BEPS Base Erosion & Profit Shifting BEPS report OECD/G20 BEPS project report 2015 CA Competent authorities CJ Contracting jurisdiction CRE Closely related enterprises CTA Covered Tax Agreement (tax treaty) DA Dependent agent This publication is the eighth 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 22 July 2010, including the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back Contracting States are generally based on the OECD Model Tax Convention (“OECD-MC”) and are then tailored to the particular economic interest of each Contracting State. (1) On 19 July 2013, the OECD published its Action Plan on Base Erosion and Profit Shifting (“BEPS”) that provides for 15 actions. The BEPS Action Plan The full OECD model convention, including the articles, commentaries, nonmember economies’ positions, and historical notes, will be published in the coming year, according to an OECD news release. Sophie Chatel, head of the OECD’s tax treaty unit, said on December 15 during the eighth installment of the OECD’s Tax Talks webcast series that the full version should be available by mid-January. 2020-04-03 · Developing countries around the world use the OECD model convention for framing their tax treaties.

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Treasury states that Australia is party to 44 such agreements.32. 2.11. The new Multilateral Tax 2 Jun 2017 Technical Briefing Note – Ireland's approach to the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS. 14 Jun 2017 OECD Tax Q&A Webinar | Multilateral BEPS Convention (MLI) tools that will facilitate the application of the convention by taxpayers and tax administrations. [OECD Tax] Model Tax Convention Lecture 1_Jae hyung J 24 Mar 2014 Commentary on Article 5 of the OECD Model Tax Convention . As noted in the BEPS Action Plan, “the spread of the digital economy also 30 Jun 2016 as countries will be able to draw on the Model, as they have previously, for tax treaty negotiations.

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Lastly, the Guidance also contains an Annex with an example of the synthesized text of the 2014 OECD Model Tax Convention as modified by the MLI. Synthesized texts would take the form of a single document or webpage. OECD’s proposal for a ’unified approach’ On 9 October 2019, the OECD released a public consultation document outlining a proposal from the OECD Secretariat for a ’unified approach‘ under Pillar One. The scope of the Secretariat Proposal covers highly digitalized business models and consumer-facing non-digitalized businesses. Table: OECD BEPS Actions and Timelines Action Plan Output Timelines Action 1 – Address the tax challenges of the digital economy Report identifying issues raised by digital economy and possible actions to address them September 2014 Action 2 – Neutralise the effects of hybrid mismatch arrangements Changes to Model Tax Convention AN ANALYSIS OF THE APPLICABILITY OF THE OECD MODEL TAX CONVENTION TO NON-OECD MEMBER COUNTRIES Journal of Economic and Financial Sciences | JEF | April 2017, 10(1), pp. 83-93 85 circumstances where more recent policy developments or tax amendments appear particularly relevant.

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The OECD Model Tax Convention and Commentary and BEPS June 2017 .

Executive summary. Lastly, the Guidance also contains an Annex with an example of the synthesized text of the 2014 OECD Model Tax Convention as modified by the MLI. Organisation of Economic Co-Operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Project identifies Action 7 to prevent the issues of artificial avoidance of PE status.
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Uncertainty was created when the OECD in 1992 revised its model convention’s commentary to exclude such rights to use. Regrettably extracts of these revisions were included also in the UN model’s commentary, although it also noted that some members disagreed with that interpretation. Model Tax Convention on Income and on Capital 2017 (Full Version) This publication is the tenth 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 as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, the Recommendation of the OECD Council, the historical notes and the background reports.

Income and on Capital.
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The OECD Model Tax Convention and Commentary and BEPS June 2017 . I. Introduction. The Organization for Economic Co-operation and Development (“OECD”) published a new edition of its condensed Income and Capital Model Convention and Commentary (the ninth edition) in 2014 which can be found here. OECD & Model Conventions.

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This shorter version contains the articles and commentaries of the Model Tax Convention on Income and Capital as it read on 21 November 2017, but without the historical notes and the background reports that are included in the full version.