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OECD considering changes to Model Tax Convention

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The OECD has launched a consultation on a series of minor changes to the OECD Model Tax Convention. The majority are minor editorial or clarificatory changes, but they do include additional commentary on:

  • the application of the articles on dividends (10) and capital gains (13) to the redemption of shares;
  • the application of the interest article (11) to accrued interest; and
  • capital gains accruing before the capital gains article (13) is included in a treaty.

Comments on this discussion draft are invited before 15 January 2014 and will be examined at meetings in February 2014. It is proposed that these changes be part of the next update to the OECD model tax convention, which is currently scheduled to be finalised in 2014.

The OECD is also inviting comments by 15 January 2014 on a discussion draft of proposed changes to Model Tax Convention provisions dealing with profits of enterprises operating ships and aircraft in international traffic and the taxation of their employees.