Q&A: The OECD's Model Tax Convention

Heather Self

The OECD Council has approved the contents of the 2014 update to the Model Tax Convention. A revised version of the Convention will be published in the next few months. This update reflects work carried out between 2010 and the end of 2013 which does not include work underway on the BEPS action plan.

What do you think the most important changes are and why?

It changes the international standard for the exchange of tax information which is very much a key topic of discussion at the moment. It broadens the scope of exchange of information requests that countries can make of each other in a double tax agreement (DTA) context. States can seek information on a group of taxpayers without naming them officially as the long as the request is not a ‘fishing expedition’.

The meaning of ‘beneficial ownership’ is clarified which makes it...

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