On 15 July 2014, the OECD Council approved the contents of the 2014 Update to the OECD Model Tax Convention. The Update will be incorporated in a revised version of the Model Tax Convention that will be published in the next few months. The 2014 Update does not include any results from the ongoing work on the BEPS Action Plan.
The 2014 Update includes the changes to Article 26 and its Commentary. It also includes the final version of a number of changes that were previously released for comments through the following discussion drafts:
- The application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention (23 April 2010).
- Revised proposals concerning the meaning of “beneficial owner” (19 October 2012).
- Revised discussion draft on tax treaty issues related to emissions permits and credits (19 October 2012).
- Tax treaty treatment of termination payments (25 June 2013).
- Technical changes to be included in the next update to the Model Tax Convention (15 November 2013).
[LTN 136, 17/7/14]