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November 4, 2026
This full version of the OECD Model Tax Convention on Income and on Capital reproduces the text as it read on 18 November 2025. It contains the Articles of the Convention, the Commentaries on each Article, the positions of non-OECD economies, the Recommendation of the OECD Council, the historical notes and the full text of background reports adopted after 1977. The Introduction explains international juridical double taxation and why bilateral tax conventions are used to remove it. Volume I sets out the Convention with its Commentaries, covering matters such as residence, permanent establishment and arbitration, while Volume II collects previous reports.
Model Tax Convention on Income and on Capital 2025 (Full Version)
Table of contents
Foreword
Volume I
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