Model Tax Convention on Income and on Capital: Condensed Version 2014

The OECD Model Tax Convention provides the basis for the negotiation and interpretation of more than 3000 tax treaties that make up a network that co-ordinate the income and corporate tax systems of most countries with the objective of removing tax barriers to cross-border trade and investment.

This publication is the ninth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the full text of the Model Tax Convention on Income and on Capital as accepted on 15 July 2014, but without the historical notes, the detailed list of conventions between OECD member countries and the background reports that are included in the full-length version, which will appear soon. Changes appearing in this edition address such issues as Exchange of Information (Article 26), the meaning of beneficial owner (Aricles 10, 11 and 12), the treatment of sportsment and entertainers (Article 17), treatment of termination payments and other technical issues.

Table of contents: 

Introduction 7
Model Convention with respect to Taxes on Income and on Capital (Articles)19
Commentaries on the Articles of the Model Tax Convention 45
-Commentary on Article 1 (Persons covered)  47
-Commentary on Article 2 (Taxes covered)   77
-Commentary on Article 3 (General definitions) 80
-Commentary on Article 4 (Resident) 85
-Commentary on Article 5 (Permanent establishment) 94
-Commentary on Article 6 (Income from immovable property) 130
-Commentary on Article 7 (Business profits) 132
-Commentary on Article 8 (Shipping, inland waters transport and air transport) 176
-Commentary on Article 9 (Associated enterprises) 183
-Commentary on Article 10 (Dividends) 187
-Commentary on Article 11 (Interest)  208
-Commentary on Article 12 (Royalties) 224
-Commentary on Article 13 (Capital gains)  243
-Commentary on Article 14 [Deleted]  255
-Commentary on Article 15 (Income from employment) 256
-Commentary on Article 16 (Director’s fees)  279
-Commentary on Article 17 (Entertainers and sportspersons)  281
-Commentary on Article 18 (Pensions) 292
-Commentary on Article 19 (Government service) 310
-Commentary on Article 20 (Students)  315
-Commentary on Article 21 (Other income) 316
-Commentary on Article 22 (Capital)  320
-Commentary on Articles 23 A and 23 B (Exemption and credit methods for eliminating double taxation) 323
-Commentary on Article 24 (Non-discrimination) 349
-Commentary on Article 25 (Mutual agreement procedure) 371
-Commentary on Article 26 (Exchange of Information) 414
-Commentary on Article 27 (Assistance in collection of taxes) 434
-Commentary on Article 28 (Members of diplomatic missions and consular posts) 443
-Commentary on Article 29 (Territorial extension) 445
-Commentary on Articles 30 and 31 (Entry into force and termination) 446
Non-OECD economies’ positions on the OECD Model Tax Convention  447
Annex – Recommendation of the OECD Council concerning the Model Tax Convention on Income and on Capital  491


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Printed & ebook, ebook only

Publication date

05 Sep 2014




Printed: 9789264211155
ebook: 9789264219373

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