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Model Tax Convention on Income and on Capital 2010 (Full Version)
OECD Publishing , Publication date:  10 Aug 2012
Pages: 2000 , Language: English
Version: Print (Paperback) + PDF
ISBN: 9789264175174 , OECD Code: 232010111P1
Price:   €325 | $455 | £292 | ¥42200 | MXN5850 , Standard shipping included!
Availability: Available
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Other languages:  French (Available)
Other Versions:  E-book - PDF Format USB Key - 2.0

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Description

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 to 1963), the detailed list of conventions between OECD member countries and the background reports. This edition of the full version is the first to be published in book form. The previous loose-leaf edition has been discontinued.

The full version of the OECD Model Tax Convention is published regularly to reflect updates. The full version is also available electronically. This electronic version includes such features as extensive internal linking, making it easy to link from an article to its commentary; fast searching capabilities; the ability for the user to attach notes to specific areas of text and cut and paste capabilities. The condensed version 2010, previously published and also available, includes only the articles, commentaries, non-member economies positions and the Recommendation of the OECD Council.


Table of contents:

Foreword
Introduction
Model  Convention
-Title and  Preamble
-Article 1. Persons covered
-Article 2. Taxes covered
-Article 3. General definitions
-Article 4. Resident
-Article 5. Permanent establishment
-Article 6. Income from immovable property
-Article 7. Business profits
-Article 8. Shipping, inland waterways transport and air transport
-Article 9. Associated enterprises
-Article 10. Dividends
-Article 11. Interest
-Article 12. Royalties
-Article 13. Capital gains
-Article 14. Independent personal services [deleted]
-Article 15. Income from employment
-Article 16. Directors’ fees
-Article 17. Artistes and Sportsmen
-Article 18. Pensions
-Article 19. Government service
-Article 20. Students
-Article 21. Other income
-Article 22. Capital
-Article 23. A and 23 B. Methods for elimination of double taxation
-Article 24. Non-discrimination
-Article 25. Mutual agreement procedure
-Article 26. Exchange of Information
-Article 27. Assistance in the collection of taxes
-Article 28. Members of diplomatic missions and consular posts
-Article 29. Territorial extension
-Article 30. Entry into force
-Article 31. Termination Commentaries on the Articles of the Model Convention
Commentaries on the Articles of the Model Convention
-Commentary on Article 1: Concerning the persons covered by the convention
-Commentary on Article 2: Concerning taxes covered by the convention
-Commentary on Article 3: Concerning general definitions
-Commentary on Article 4: Concerning the definition of resident
-Commentary on Article 5: Concerning the definition of permanent establishment
-Commentary on Article 6: Concerning the taxation of income from immovable property
-Commentary on Article 7: Concerning the taxation of business profits
-Commentary on Article 8: Concerning the taxation of profits from shipping, inland waterways transport and air transport
-Commentary on Article 9: Concerning the taxation of associated enterprises
-Commentary on Article 10: Concerning the taxation of dividends
-Commentary on Article 11: Concerning the taxation of interest
-Commentary on Article 12: Concerning the taxation of royalties
-Commentary on Article 13: Concerning the taxation of capital gains
-Commentary on Article 14: Concerning the taxtion of  independent personal services [deleted]
-Commentary on Article 15: Concerning the taxation of income from employment
-Commentary on Article 16: Concerning the taxation of directors’ fees
-Commentary on Article 17: Concerning the taxation of artistes and sportsmen
-Commentary on Article 18: Concerning the taxation of pensions
-Commentary on Article 19: Concerning the taxation of remuneration in respect of government service
-Commentary on Article 20: Concerning the taxation of students
-Commentary on Article 21: Concerning the taxation of other income
-Commentary on Article 22: Concerning the taxation of capital
-Commentary on Article 23 A and 23 B: Concerning the methods for elimination of double taxation
-Commentary on Article 24: Concerning non-discrimination
-Commentary on Article 25: Concerning the mutual agreement procedure
-Commentary on Article 26: Concerning the exchange of information
-Commentary on Article 27: Concerning the assistance in the collection of taxes
-Commentary on Article 28: Concerning members of diplomatic missions and consular posts
-Commentary on Article 29: Concerning the territorial extension of the convention
-Commentary on Article 30 and 31: Concerning the entry into force and the termination of the convention
Non-OECD Economies’ Positions on the OECD Model Tax Convention
-Introduction 
-Positions on article 1 (Persons covered) and its commentary
-Positions on article 2 (Taxes covered) and its commentary
-Positions on article 3 (General definitions) and its commentary
-Positions on article 4 (Resident) and its commentary
-Positions on article 5 (Permanent establishment) and its commentary
-Positions on article 6 (Income from immovable property) and its commentary
-Positions on article 7 (Business profits) and its commentary
-Positions on article 8 (Shipping, inland waterways transport and air transport) and its commentary
-Positions on article 9 (Associated enterprises) and its commentary
-Positions on article 10 (Dividends) and its commentary
-Positions on article 11 (Interest) and its commentary
-Positions on article 12 (Royalties) and its commentary
-Positions on article 13 (Capital gains) and its commentary
-Positions on article 14 (Independent personal services) and its commentary [deleted]
-Positions on article 15 (Income from employment) and its commentary
-Positions on article 16 (Directors’ fees) and its commentary
-Positions on article 17 (Artistes and sportsmen) and its commentary
-Positions on article 18 (Pensions) and its commentary
-Positions on article 19 (Government service) and its commentary
-Positions on article 20 (Students) and its commentary
-Positions on article 21 (Other income) and its commentary
-Positions on article 22 (Capital) and its commentary
-Positions on article 23 A and 23 B (Exemption method and credit method) and its commentary
-Positions on article 24 (Non-discrimination) and its commentary
-Positions on article 25 (Mutual agreement procedure) and its commentary
-Positions on article 26 (Exchange of information) and its commentary
-Positions on article 28 (Members of diplomatic missions and consular posts) and its commentary
-Positions on article 29 (Territorial extension) and its commentary
Previous Reports related to the Model Tax  Convention
-R(1). Transfer pricing, corresponding adjustments and the mutual agreement procedure 
-R(2). The taxation of income derived from the leasing of industrial, commercial or scientific equipment 
-R(3). The taxation of income derived from the leasing of containers 
-R(4). Thin capitalisation  
-R(5). Double taxation conventions and the use of base companies 
-R(6). Double taxation conventions and the use of conduit companies 
-R(7). The taxation of income derived from entertainment, artistic and sporting activities
-R(8). Tax treaty override 
-R(9). The 183 Day rule: some problems of application 
-R(10). The tax treatment of software  
-R(11). Triangular cases 
-R(12). The tax treatment of employees’ contributions to foreign pension schemes 
-R(13). Attribution of income to permanent establishments  
-R(14). Tax sparing a reconsideration 
-R(15). The application of the OECD Model Tax Convention to partnerships 
-R(16). Issues related to Article 14 of the Model Tax Convention 
-R(17). Restricting the entitlement to treaty benefits 
-R(18). Treaty characterisation issues arising from e-commerce 
-R(19). Issues arising under Article 5 (permanent establishment) of the Model Tax Convention 
-R(20). Cross-border income tax issues arising from employee stock-option plans  
-R(21). Improving the resolution of tax treaty 
-R(22). Application and interpretation of Article 24 (non-discrimination) 
-R(23). Tax treaty issues related to REITs 
-R(24). The granting of treaty benefits with respect to the income of collective investment vehicles  
Appendices
-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

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