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Model Tax Convention on Income and on Capital: Condensed Version, July 2010

Model Tax Convention Condensed Version July 2010    
Format Softcover - PDF version available on request when you purchase the softcover
Catalogue No. 232010081P
Pages 466
Language English; Aussi disponible en français (French edition not yet released)
Price $104.00
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Published by the Organisation for Economic Co-operation and Development, 2010.


The Model Tax Convention on Income and on Capital is used by both OECD member countries, including Canada, and non-member countries as the basis for the negotiation, application and interpretation of their bilateral tax treaties. The Model and the worldwide network of over 3000 treaties based upon it provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. They thus help to prevent those problems from operating as obstacles to the free movement of goods, services, capital and persons between countries.

This publication is the eighth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. It contains the full text of the Articles, Commentary, and Country Positions of the Model Tax Convention as read on July 22, 2010, after the adoption of the eighth update by the Council of the OECD. The 2010 version includes a new Article 7 (Business Profits), which completes the Committee's work on the attribution of profits to permanent establishments. It also introduces new text relating to the granting of the benefits of tax treaties with respect to the income of collective investment vehicles, the application of tax treaties to State-owned entities (including sovereign wealth funds), tax treaty issues relating to common telecommunications transactions, and the application of Article 15 (Income from Employment) to employees who work for a short duration in a foreign country.

This shorter version contains the full text of the Model Tax Convention, but without the historical notes, the detailed list of tax conventions between OECD member countries and the background reports that are included in the loose-leaf version.

  • Introduction
  • Model Convention with respect to Taxes on Income and on Capital
  • Commentaries on the Articles of the Model Tax Convention
  • Non-OECD economies' positions on the OECD Model Tax Convention
  • Annex: Recommendations of the OECD Council concerning the Model Tax Convention on Income and on Capital
The OECD Model Tax Convention on Income and on Capital is the benchmark for negotiating, implementing and interpreting tax conventions.

Also available:
Model Tax Convention on Income and on Capital Volumes I and II: Loose-leaf Edition
Model Tax Convention on Income and on Capital 2008, Electronic Version (eMTC) - USB Memory Stick.

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This page last modified: September 23, 2010

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