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OECD MODEL TAX CONVENTION 2010 PDF

Friday, October 4, 2019


ON INCOME AND CAPITAL. [as they read on 22 July ] This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting . Contracting States, more recent conventions usually apply to “residents” of one or both Application of the OECD Model Tax Convention to Partnerships”,1 the. 1. THE UPDATE TO THE MODEL TAX CONVENTION approved by the OECD Council on 22 July TABLE OF CONTENTS.


Oecd Model Tax Convention 2010 Pdf

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Publication Date: 17 August Pages: Model Tax Convention on Income and on Capital. Condensed Version. This publication is. This full version contains the full text of the Model Tax Convention on OECD. 06 Aug pages. ISBN: (PDF). The Model Tax Convention, and the worldwide network of treaties based on it OECD. 17 Aug pages. ISBN: (PDF).

These new guidelines will help both developed and developing countries ensure that MNEs do not use transfer pricing to shift profits into low-tax jurisdictions and, at the same time, that they will not be subject to double taxation.

The guidelines should help reduce and resolve disputes between tax authorities.

Of relevance in this context are the recommendations issued by the Committee on Fiscal Affairs in February on mandatory dispute resolution mechanisms. The revised guidelines have benefitted from input from non-OECD economies, and the OECD now has in place an extensive program to help those countries apply the guidelines. The Report on the Attribution of Profits to Permanent Establishments, approved in its [original form] http: In order to fully implement the conclusions of the Report, the Committee on Fiscal Affairs decided to draft a new version of Article 7, which now appears in the update to the Model Tax Convention.

The Committee also decided to publish simultaneously with that update a [modified version] http: The Hon.

Turnquest has had wide business experience having led international sales and manufacturing operations in several countries.

Following successful re-election on May 10th, , Hon. He is married to Sonia Turnquest and together they have two children, Kevin and Nathalie.

OECD Model Tax Convention 2010 and Other Updates

He has also been advisor in several major acquisitions and mergers within The Bahamas, and also in acquisitions by or mergers with regional entities. Highly valued by industry to navigate complexities and pitfalls to achieve strategic business objectives, John has held a range of non-executive directorships of financial institutions and publicly listed companies, and he has served as member and chair of audit committees.

John also has a history of national contribution. In year he was private sector legal advisor to the Government on major financial services legislative reforms, and over the years has been a member of various national or industry boards, including: He is a Barrister-at-Law having been called to the Bahamas Bar in Symonette is a respected and experienced politician having served in many governmental capacities for approximately thirty 30 years.

His political career began in where he was appointed to the Senate of The Bahamas serving in this capacity for two consecutive five year terms. In , he was elected as the Member of Parliament for the Montagu Constituency.

Valdez K. Russell serves as the principal of VKR Insights, a communications and reputation management agency. Throughout his professional career, Valdez has been instrumental in facilitating public relations and communication strategies to help individuals and organizations to build relationships and influence change.

Valdez sharpened his communications and qualitative research skills throughout his career as a college administrator and educator. He was instrumental in the development of international partnerships with colleges and universities. Valdez represented the College and The Bahamas internationally to promote research in the areas of maritime studies, banking and finance, healthcare and sustainable island living.

For the past decade, Valdez has served as a leadership facilitator and corporate trainer, where he helps individuals to develop their leadership skills. He has presented leadership, communications and motivational presentations throughout The Bahamas, Canada, the Caribbean, and the United States and the United Arab Emirates.

Covering the latest taxation issues and challenges in the UK

These anti-treaty shopping provisions still do not offer a universal solution to solving the treaty shopping problem. Thus, they form only a base framework of possible approaches for prevention of treaty shopping.

The OECD commentary states that a combination of different measures may have to be used by the contracting jurisdictions in order for various avoidance schemes to be prevented. Christiana H. Panayi, page 43 28 Opt. Miller and L. Oats, p. Although, a legal definition of the term is not to be found in any DTR convention some understanding on the term can be derived by Art. Although the factual content of the case is long and complicated, in general, it focuses on to the main question whether a conduit legal entity, established especially for the purposes of a particular deal, may be interpreted as a beneficial owner of an interest payment to be received by it, and further transmitted through it, according to a double tax treaty.

The judges' decision had been highly 30 Indofood International Finance Ltd v. Societe Bank of Scotland, no. Baker The immediate recipient of the income in this situation qualifies as a resident but no potential double taxation arises as a consequence of that status since the recipient is not treated as the owner of the income for tax purposes in the State of residence. It would be equally inconsistent with the object and purpose of the Convention for the State of source to grant relief or exemption where a resident of a Contracting State, … simply acts as a conduit for another person who in fact receives the benefit of the income concerned.

For these reasons, the [Conduit Companies Report] concludes that a conduit company cannot normally be regarded as the beneficial owner if, though the formal owner, it has, as a practical matter, very narrow powers which render it, in relation to the income concerned, a mere fiduciary or administrator acting on account of the interested parties.

It actually comes from a letter written by the Indonesian tax authority in response to the question of the UK Court of Appeal if the former is ready to interpret the conduit legal entity on the case as beneficial owner of the interest. VI, No. The Court noted that Philip Baker suggests that the term should be accorded an international fiscal meaning not derived from the domestic laws of contracting states.

In order for this approach to work a current info of the identity of the shareholders should be provided. It is meant to be used primarily in treaties with one of the parties being a low or no-tax jurisdiction, where a the risk of establishment of conduit legal entities is bigger. The reduction is most likely to be made by payments of interest, royalties or emission of obligations or any other tax deductible form.

Miller, L. The limitation usually encompasses persons who are obliged to pay taxes because of residence, domicile, place of management etc. Oats, p 42 Art.

This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein. This is usually made possible by making use of not having to pay dividends direct conduit method or by transferring income making use of tax deduction for expenses stepping stone method or by establishment of a specific conduit company which is tax-exempt according to the treaty.

The exclusion method provides that countries may just decide to exclude particular forms of legal entities and unable them to benefit from the convention.

The scope of exclusion may encompass only some or all types of income, which is why the exclusion provision offers higher chances for soft-adjustment than the limitation of residence above Both, the U.

The provision is also incapable of dealing with stepping-stone conduits and is usually hard to be administered, because tax legislation 45 Opt.

Tax treaties

Panayi, p. Supplementary tests Because of the fact that all the approaches above may lead to restrictions on bona fide 48 legal entities, which are not conduits established for tax avoidance purposes, application of supplementary tests is recommended. Their goal is to tell apart bona fide from conduit structures. Challenges on taxation in the UKCS and oil and gas production Following the privatisation of the British National Oil Company BNOC in , and because of the introduction of the current licensing regime, the UK government relies mainly on taxation to share the wealth from the petroleum industry.

Mutually beneficial agreement can be achieved only through designing of a competitive tax system which should be capable to both answer the current industry's needs and attract new investors. If the taxation is too rough, the willingness of the companies to invest in exploration, extraction and expansion may be restricted which usually results in investments being made in another tax jurisdictions with more preferable tax systems or in suspension and manipulation of the established production, which may become ineffective.

Haug, p.

Principles, Problems and Practice, The [e-book]. Available from: The PRT is an oil and gas field based tax. The profits from every tax field which is licensed before It does not apply to fields licensed after this date.

Covering the latest taxation issues and challenges in the UK

Related Valdez K. Russell serves as the principal of VKR Insights, a communications and reputation management agency. Throughout his professional career, Valdez has been instrumental in facilitating public relations and communication strategies to help individuals and organizations to build relationships and influence change.

Valdez sharpened his communications and qualitative research skills throughout his career as a college administrator and educator.

He was instrumental in the development of international partnerships with colleges and universities. Valdez represented the College and The Bahamas internationally to promote research in the areas of maritime studies, banking and finance, healthcare and sustainable island living.

For the past decade, Valdez has served as a leadership facilitator and corporate trainer, where he helps individuals to develop their leadership skills. He has presented leadership, communications and motivational presentations throughout The Bahamas, Canada, the Caribbean, and the United States and the United Arab Emirates.

In celebration of the Bahamas 40th Anniversary of Independence, The Tribune Newspaper recognized Valdez as one of 40 Bahamians under years old shaping education in the country. Valdez brings a wealth of knowledge and experience to leadership, communications and brand reputation management. He continues to promote national development through preparing individuals to be globally competitive and economically independent.

While at the IEA, he authored papers on the social value of finance, the role of offshore centers, the regulation of online platforms, and the taxation of capital income, among others. Zuluaga is a prolific public speaker as well as a former lecturer in economics at the University of Buckingham. Related Christina R. Christina R. Rolle has over 20 years of experience in the financial services industry. Over the course of her career, Ms. Rolle has acted as Director and Deputy CEO for a prominent international private bank and held various senior managerial positions with local and other international institutions including Head of Trust and Fiduciary, Head of Risk, Compliance and Corporate Governance and Manager of Banking Services.

She is highly skilled in quantitative and statistical analysis, marketing, operations and business strategy.Mutually beneficial agreement can be achieved only through designing of a competitive tax system which should be capable to both answer the current industry's needs and attract new investors. The guidelines should help reduce and resolve disputes between tax authorities.

Societe Bank of Scotland, no.

OECD Model Tax Convention on Income and on Capital July 2010 (incl commentary)

By joseph lubega. In celebration of the Bahamas 40 th Anniversary of Independence, The Tribune Newspaper recognized Valdez as one of 40 Bahamians under years old shaping education in the country. For many developing states treaty shopping might be regarded as an opportunity to draw investments. In the last part of this essay a similar issue about the unstable amount of revenue coming from the UKCS is observed.

Smith is currently in retirement since June, Hal earned his J.

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