The Organisation for Economic Cooperation and Development (OECD)
on Thursday 25 April 2019, published the full version of its 2017
Model Tax Convention on Income and Capital, the tenth edition.
This full version contains Articles, Commentaries, non-member
economies' positions, the Recommendation of the OECD Council,
the historical notes and the background reports. It incorporates
some of the measures from the OECD BEPS Project including hybrid
mismatch, treaty shopping, artificial avoidance of permanent
establishment and dispute resolution.
The model convention is designed to provide a standard template
for concluding avoidance of double taxation treaties between
countries to facilitate economic development, limit double
taxation, prevent double non-taxation, and enhance mutual
agreements and assistance on tax matters.