Updated OECD model tax treaty incorporates BEPS changes

The OECD today published the condensed version of the  2017 edition of the OECD Model Tax Convention, used by many nations when negotiating bilateral tax treaties.

Among other revisions, the latest version of the treaty incorporates changes agreed to by nations in 2015 as a result of the OECD/G20 base erosion profit shifting (BEPS) project. These changes are designed to curtail tax avoidance by multinationals and improve resolution of cross-border tax disputes.

These new treaty reflects BEPS agreements on countering hybrid mismatches, preventing tax treaty shopping and other tax treaty abuse, expanding the definition of permanent establishment, and improving the mutual agreement procedure (MAP) for resolving tax treaty disputes, including MAP arbitration.

An OECD official said last week that the full version of the Convention, which includes commentaries, non-member country positions, and historical notes, will be published in January.

According to the OECD, over 3000 tax treaties are based on the OECD Model.

 

 

 

 

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