Part of Springer Nature. This condensed version includes the text of the Model Tax Convention as it read on 15 July 2014 after the adoption of the ninth update by the Council of the OECD. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 22 July 2010. This service is more advanced with JavaScript available, International Tax Evasion in the Global Information Age Indeed, to the extent that taxes have been levied on the increased profits in the first-mentioned State, that State may be considered to have included in the profits of an enterprise of that State, and to have taxed, profits on which an enterprise of the other State has been charged to tax. ARTICLES OF THE OECD MODEL TAX CONVENTION ON INCOME AND CAPITAL [as they read on 22 July 2010] SUMMARY OF THE CONVENTION Title and Preamble Chapter I SCOPE OF THE CONVENTION Article 1 Persons covered Article 2 Taxes covered Chapter II DEFINITIONS Article 3 General definitions Article 4 Resident Article 5 Permanent establishment Chapter III TAXATION OF INCOME Article 6 Income … The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions, plays a crucial role in removing tax related barriers to cross border trade and investment. One of the themes of this research is that these policy challenges continue to be ignored by the OECD and, more recently, by the Global Forum on Transparency and Exchange of Information for Tax Purposes and the G20 in favour of solutions that seek tax harmonization in the form of treaties and model agreements. The 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. Model Tax Convention on Income and on Capital: Condensed Version 2014 Commentary on article 9: concerning the taxation of associated enterprises State B is therefore committed to make an adjustment of the profits of the affiliated company only if it considers that the adjustment made in State A is justified both in principle and as regards the amount. and in either case conditions are made or imposed bet ween the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. This shorter version contains the full text of the Model Tax Convention, but without the historical notes, the detailed list of tax treaties between OECD member countries and the background reports that are included in the full-length loose-leaf and electronic versions. The position has still not been restored exactly to what it would have been had the transactions taken place at arm’s length prices because, as a matter of fact, the money representing the profits which arc the subject of the adjustment is found in the hands of enterprise Y instead of in those of enterprise X. pp 257-281 | OECD iLibrary As discussed in the Committee on Fiscal Affairs’ Report on “, 8. Hungary and Slovenia reserve the right to specify in paragraph 2 that a correlative adjustment will be made only if they consider that the primary adjustment is justified. Contracting States may also wish to address this issue through a provision limiting the length of time during which a primary adjustment may be made pursuant to paragraph 1; such a solution avoids the economic double taxation that may otherwise result where there is no corresponding adjustment following the primary adjustment. It should be noted that nothing in paragraph 2 prevents such secondary adjustments from being made where they are permitted under the domestic laws of Contracting States. endstream endobj 345 0 obj <>stream This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. Moreover, the United States faced economic, political, and historical challenges in dealing with Switzerland over EOI. The 2017 edition of the OECD Model mainly reflects a consolidation of the treaty-related measures resulting from the work on the OECD/G20 BEPS Project under Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements), Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances), Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status) and Action 14 (Making Dispute Resolution More Effective). Because the economic and tax environment is constantly changing, articles and commentary in this model convention are periodically updated. h��V�o�0�W��I�l'v>� “The Swiss Twist: The Exchange-of-Information Provisions of the Canada–Switzerland Protocol” (2012) 60, McCracken, Sara K. “Going, Going, Gone. Over 10 million scientific documents at your fingertips. 6. Model Tax Convention on Income and on Capital: Condensed Version 2017 Commentary on Article 7. 19. For instance, in appropriate cases, the character of the instrument (as debt) and the character of the payment (as interest) may be unchanged, but the taxing State may defer the deduction for interest paid that otherwise would be allowed in computing the borrower’s net income.

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