This document consolidates the specific legal positions and reservations of non-OECD economies regarding the OECD Model Tax Convention. It details widespread disagreements on key Articles, including Article 5 (Permanent Establishment), where many states seek broader taxing rights over services and natural resource exploration. Significant reservations are noted for Article 12 (Royalties), with many economies—including India, Brazil, and Russia—insisting on source-based taxation for technical fees and equipment leasing. Other critical areas include Article 7 (Business Profits), where the pre-2010 update version is preferred, and Article 10 (Dividends), regarding branch profits tax. These positions highlight the efforts of non-member states to protect domestic tax bases while participating in the global harmonisation of tax treaties.