Model Tax Convention on Income and on Capital

Cross-border investment would be seriously impeded if there was a danger that the returns on such investment were taxed twice, both where the money was invested and in the country of residence of the investors. The OECD Model Tax Convention and the worldwide network of tax treaties based upon it help to avoid that danger by providing clear consensual rules for taxing income and capital. For most types of income, especially business profits and investment income, double taxation is avoided in treaties based on the OECD Model Tax Convention by allocating taxing rights between the resident and source countries and by requiring the former to eliminate double taxation where there are competing taxing rights. Most bilateral tax treaties follow both the principles and the detailed provisions of the OECD Model. There are close to 350 treaties between OECD Member countries and over 1500 world-wide which are based on the Model, and it has had considerable influence on the bilateral treaties between non-member countries. The Model is presented in two Volumes. Volume I includes the Introduction, Model Convention and the Commentary. Volume II includes the new section on the positions of the non-member countries, reprints of previous reports dealing with tax conventions that the Committee on Fiscal Affairs has adopted since 1977, the list of tax conventions concluded between Member countries and the text of the Council Recommendation on the Model Tax Convention.Organisation for Economic Co-operation and Development Staff is the author of 'Model Tax Convention on Income and on Capital' with ISBN 9789264176454 and ISBN 9264176454.