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This document is the condensed version of the OECD Model Tax Convention on Income and on Capital, updated as of November 21, 2017. It outlines the standardized international framework used by countries to negotiate bilateral tax treaties, aiming to eliminate juridical double taxation without creating opportunities for tax evasion or avoidance. It establishes definitions, rules for taxing various forms of income and capital, methods for tax relief (exemption and credit), and special provisions for non-discrimination, mutual agreement, and information exchange.

Model Tax Convention on Income and on Capital

Condensed Version

21 November 2017

Introduction

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 - [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

Terminal Clause

Forward

This is the tenth edition of the condensed version of the publication entitled Model Tax Convention on Income and on Capital, first published in 1992 and periodically updated since then.

This condensed version includes the text of the Model Tax Convention as it read on 21 November 2017 after the adoption of the tenth update by the Council of the OECD. Historical notes included in Volume I of the full version and the background reports that are included in Volume II of the full version have not been reproduced in this version.

Acknowledgements

The OECD Centre for Tax Policy and Administration would like to express its gratitude to Jacques Sasseville for his invaluable contributions over more than 20 years to the development and publication of this and earlier editions of the OECD Model Tax Convention.

Contents

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Acknowledgements

Introduction