Publication of comments received on the OECD Model Tax Convention 2017 Update

The OECD published the comments received on the 2017 update on the Model Tax Convention (“MTC”). Draft contents was released on 11 July 2017 with respect to the changes in relation to paragraph 13 of the Commentary on Article 4 MTC (tie-breaker rule for Article 4(2)c MTC; changes to paragraphs 17 and 19 (regarding the meaning of ‘habitual abode’); the addition of new paragraph 1.1 to the Commentary on Article 5 MTC (relevant for interpretation of the ‘permanent establishment’ definition); and, the deletion of parenthetical reference from subparagraph 2a) of Article 10.

The public comments received by the OECD on the above changes to the Model Tax Convention are available to download at the following link.

OECD plans to approve and publish the full contents of the OECD Model 2017 Update at the end of year.



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