Stakeholders engage on changes to OECD Model Tax Convention

The OECD has received comments from 22 stakeholders including the Big 4, Mexican Institute of Public Accountants, International Chamber of Commerce, European Business Initiative on Taxation, Business at OECD (BIAC), and Vienna University of Economics and Business, among others.

The OECD has received input from 22 stakeholders on the proposed tax changes to the commentaries on Article 9 of the OECD Model Tax Convention.

Comments on these tax changes were invited by the OECD Secretariat in March this year. The tax changes put forward in this discussion draft are expected to be included in the next update to the OECD Model Tax Convention.

The OECD has received comments from 22 stakeholders including the Big 4, Mexican Institute of Public Accountants, International Chamber of Commerce, European Business Initiative on Taxation, Business at OECD (BIAC), and Vienna University of Economics and Business, among others.

Working Party 1 will consider these comments as it finalizes its work in this area with the expectation that revised commentaries will be included in the next update of the OECD Model Convention.

Article 9 of the OECD Model Tax Convention deals with the taxation of transactions between associated enterprises. Working Party 1 on Tax Conventions and Related Questions, in consultation with Working Party 6 and the Forum on Tax Administration’s MAP Forum, has recently undertaken work on the Commentary on Article 9 to clarify its application, especially as it relates to domestic laws on interest deductibility.

The work is closely linked to the report Transfer Pricing Guidance on Financial Transactions published in February last year.