Model Tax Convention on Income and on Capital: Volume I and II, (updated 21 November 2017)

Foreword
Acknowledgement
Table of contents
Volume I
	Introduction
		A. Historical background
		B. Influence of the OECD Model Convention
		C. Tax policy considerations that are relevant to the decisionof whether to enter into a tax treaty or amend an existingtreaty
		D. Presentation of the Model Convention
	Model Convention with Respect to Taxes on Income and on Capital
		Summary of the convention
		Title and Preamble
		Chapter I. Scope of the convention
			Article 1. Persons covered
			Article 2. Taxes covered
		Chapter II. Definitions
			Article 3. General definitions
			Article 4. Resident
			Article 5. Permanent establishment
		Chapter III. Taxation of income
			Article 6. Income from immovable property
			Article 7. Business profits
			Article 8. International shipping and air transport
			Article 9. Associated enterprises
			Article 10. Dividends
			Article 11. Interest
			Article 12. Royalties
			Article 13. Capital gains
			Article 14. Independent Personal Services [Deleted]
			Article 15. Income from employment
			Article 16. Directors’ fees
			Article 17. Entertainers and sportspersons
			Article 18. Pensions
			Article 19. Government service
			Article 20. Students
			Article 21. Other income
		Chapter IV. Taxation of capital
			Article 22. Capital
		Chapter V. Methods for elimination of double taxation
			Article 23 A. Exemption method
			Article 23 B. Credit method
		Chapter VI. Special provisions
			Article 24. Non-discrimination
			Article 25. Mutual agreement procedure
			Article 26. Exchange of information
			Article 27. Assistance in the collection of taxes
			Article 28. Members of diplomatic missions and consular posts
			Article 29. Entitlement to benefits
			Article 30. Territorial extension
		Chapter VII. Final provisions
			Article 31. Entry into force
			Article 32. Termination
	Commentaries on the Articles of the Model Tax Convention
		Commentary on Article 1
		Commentary on Article 2
		Commentary on Article 3
		Commentary on Article 4
		Commentary on Article 5
		Commentary on Article 6
		Commentary on Article 7
	Commentary on Article 8
		Commentary on Article 9
		Commentary on Article 10
		Commentary on Article 11
		Commentary on Article 12
		Commentary on Article 13
		Commentary on Article 14 [Deleted]
		Commentary on Article 15
		Commentary on Article 16
		Commentary on Article 17
		Commentary on Article 18
		Commentary on Article 19
		Commentary on Article 20
		Commentary on Article 21
		Commentary on Article 22
		Commentary on Articles 23 A and 23 B
		Commentary on Article 24
		Commentary on Article 25
		Commentary on Article 26
		Commentary on Article 27
		Commentary on Article 28
		Commentary on Article 29
		Commentary on Article 30
		Commentary on Articles 31 and 32
	non-OECD economies\' Positions on the OECD Model Tax Convention
		Introduction
		Positions on Article 1 and its commentary
		Positions on Article 2 and its commentary
		Positions on Article 3 and its commentary
		Positions on Article 4 and its commentary
		Positions on Article 5 and its commentary
		Positions on Article 6 and its commentary
		Positions on Article 7 and its commentary
		Positions on Article 8 and its commentary
		Positions on Article 9 and its commentary
		Positions on Article 10 and its commentary
		Positions on Article 11 and its commentary
		Positions on Article 12 and its commentary
		Positions on Article 13 and its commentary
		Positions on Article 14 and its commentary [Deleted]
		Positions on Article 15 and its commentary
		Positions on Article 16 and its commentary
		Positions on Article 17 and its commentary
		Positions on Article 18 and its commentary
		Positions on Article 19 and its commentary
		Positions on Article 20 and its commentary
		Positions on Article 21 and its commentary
		Positions on Article 22 and its commentary
		Positions on Articles 23 A and 23 B and its commentary
		Positions on Article 24 and its commentary
		Positions on Article 25 and its commentary
		Positions on Article 26 and its commentary
		Positions on Article 28 and its commentary
		Positions on Article 29 and its commentary
		Positions on Article 30 and its commentary
Volume II
	Table of contents
	Previous reports related to the Model Tax Convention
		Transfer Pricing, Corresponding Adjustments and the Mutual Agreement Procedure
		The Taxation of Income Derived from the Leasing of Industrial, Commercial or Scientific Equipment
		The Taxation of Income Derived from the Leasing of Containers
		Thin Capitalisation
		Double Taxation Conventionsand the Use of Base Companies
		Double Taxation Conventionsand the Use of Conduit Companies
		The Taxation of Income Derivedfrom Entertainment, Artistic and Sporting Activities
		Tax Treaty Override
		The 183 Day Rule: Some Problems of Application and Interpretation
		The Tax Treatment of Software
		Triangular Cases
		The Tax Treatmentof Employees’ Contributions to Foreign Pension Schemes
		Attribution of Income to Permanent Establishments
		Tax Sparing: a Reconsideration
		The Application of the OECD Model Tax Convention to Partnerships
		Issues Related to Article 14 of the OECD Model Tax Convention
		Restricting the Entitlement to Treaty Benefits
		Treaty Characterisation Issues Arising from E-Commerce
		Issues Arising under Article 5 (Permanent Establishment) of the Model Tax Convention
		Cross-border Income Tax Issues Arising from Employee Stock-Option Plans
		Improving the Resolution of Tax Treaty Disputes
		Application and Interpretation of Article 24 (Non-Discrimination)
		Tax Treaty Issues Related to REITs
		The Granting of Treaty Benefits with respect to the Income of Collective Investment Vehicles
		Tax Treaty Issues Related to Emissions Permits/Credits
		Issues Related to Article 17 of the OECD Model Tax Convention
	Appendix. Recommendation of the OECD Council concerning
the Model Tax Convention on income and on capital