Model Tax Convention on Income and on Capital 2014 (Full Version)

Volume I
Introduction
A. Historical background
B. Influence of the OECD Model Convention
C. Presentation of the Model Convention
Model Convention
Commentaries on the Articles of the Model Convention
-Commentary on Article 1
-Commentary on Article 2
-Commentary on Article 3
-Commentary on Article 4
-Commentary on Article 5
-Commentary on Article 6
-Commentary on Article 7
-Commentary on Article 8
-Commentary on Article 9
-Commentary on Article 10
-Commentary on Article 11
-Commentary on Article 12
-Commentary on Article 13
-Commentary on Article 14
-Commentary on Article 15
-Commentary on Article 16
-Commentary on Article 17
-Commentary on Article 18
-Commentary on Article 19
-Commentary on Article 20
-Commentary on Article 21
-Commentary on Article 22
-Commentary on Articles 23 A and 23 B
-Commentary on Article 24
-Commentary on Article 25
-Commentary on Article 26
-Commentary on Article 27
-Commentary on Article 28
-Commentary on Article 29
-Commentary on Articles 30 and 31
Non-OECD Economies’ Positions on the OECD Model Tax Convention
-Introduction
-Positions on Article 1 and its commentary
-Positions on Article 2 and its commentary
-Positions on Article 3 and its commentary
-Positions on Article 4 and its commentary
-Positions on Article 5 and its commentary
-Positions on Article 6 and its commentary
-Positions on Article 7 and its commentary
-Positions on Article 8 and its commentary
-Positions on Article 9 and its commentary
-Positions on Article 10 and its commentary
-Positions on Article 11 and its commentary
-Positions on Article 12 and its commentary
-Positions on Article 13 and its commentary
-Positions on Article 14 and its commentary
-Positions on Article 15 and its commentary
-Positions on Article 16 and its commentary
-Positions on Article 17 and its commentary
-Positions on Article 18 and its commentary
-Positions on Article 19 and its commentary
-Positions on Article 20 and its commentary
-Positions on Article 21 and its commentary
-Positions on Article 22 and its commentary
-Positions on Articles 23 A and 23 B and its commentary
-Positions on Article 24 and its commentary
-Positions on Article 25 and its commentary
-Positions on Article 26 and its commentary
-Positions on Article 28 and its commentary
-Positions on Article 29 and its commentary
Volume II
Previous reports related to the Model Tax Convention
-Transfer pricing, corresponding adjustments and themutual agreement procedure
-The taxation of income derived from the leasing of industrial, commercial or scientific equipment
-The taxation of income derived from the leasing of containers
-Thin capitalisation
-Double taxation conventions and the use of base companies
-Double taxation conventions and the use of conduit companies
-The taxation of income derived from entertainment, artistic and sporting activities
-Tax treaty override
-The 183 Day rule: some problems of application
-The tax treatment of software
-Triangular cases
-The tax treatment of employees’ contributions to foreign pension schemes
-Attribution of income to permanent establishments
-Tax sparing a reconsideration
-The application of the OECD Model Tax Convention to partnerships
-Issues related to Article 14 of the Model Tax Convention
-Restricting the entitlement to treaty benefits
-Treaty characterisation issues arising from e-commerce
-Issues arising under Article 5 (permanent establishment) of the Model Tax Convention
-Cross-border income tax issues arising from employee stock-option plans
-Improving the resolution of tax treaty disputes
-Application and interpretation of Article 24 (non-discrimination)
-Tax treaty issues related to REITs
-The granting of treaty benefits with respect to the income of collective investment vehicles
-Tax Treaty Issues Related to Emissions Permits/Credits
-Issues Related to Article 17 of the OECD Model Tax Convention
Appendix I. List of tax conventions on income and on capital between OECD member countries
Appendix II. Recommendation of the OECD Council concerning the Model Tax Convention on income and on capital