Model Tax Convention on Income and on Capital: Condensed Version 2014
By: OECD
About This Book
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.
AI Overview
The "Model Tax Convention on Income and on Capital: Condensed Version 2014" by the Organisation for Economic Co-operation and Development (OECD) is not a book in the traditional sense but rather a comprehensive document outlining a framework for international taxation. Here is a detailed overview of its key themes, structure, and critical reception:
Key Themes
Purpose: The primary purpose of the OECD Model Tax Convention is to provide a uniform basis for settling the most common problems that arise in the field of international juridical double taxation. It aims to clarify, standardize, and confirm the fiscal situation of taxpayers engaged in commercial, industrial, financial, or other activities in other countries.
Double Taxation: The convention addresses the issue of double taxation, which can create obstacles to the development of economic relations between countries. It provides common solutions to identical cases of double taxation, ensuring that member countries can apply these solutions uniformly.
Articles and Commentaries: The document includes various articles that cover different aspects of international taxation, such as the taxation of income from immovable property, dividends, interest, royalties, and capital gains. Each article is accompanied by commentaries that provide detailed explanations and guidance on their application.
Updates and Revisions: The 2014 version includes updates to previous versions, particularly in areas such as Article 26 (Exchange of Information) and its commentary, as well as changes related to Article 17 (Artistes and Sportsmen), the meaning of "beneficial owner," and tax treaty issues related to emissions permits and credits.
Structure
The document is structured around a series of articles, each addressing a specific aspect of international taxation. The articles are accompanied by commentaries that provide detailed explanations and guidance on their application. The structure ensures that member countries can easily understand and implement the provisions to avoid double taxation and fiscal evasion.
Critical Reception
Given its nature as a model convention rather than a book, there isn't a traditional critical reception in the form of book reviews. However, the OECD Model Tax Convention is widely regarded as a foundational document in international taxation. It has been adopted by many countries as a basis for their bilateral tax treaties, and its updates reflect ongoing efforts to address emerging issues in international taxation.
Conclusion
The "Model Tax Convention on Income and on Capital: Condensed Version 2014" by the OECD is a critical tool for international taxation, providing a standardized framework to address double taxation and ensure fiscal clarity across borders. Its comprehensive structure and regular updates make it an essential reference for tax authorities and policymakers worldwide.