The OECD Council approved the 2014 Update to the OECD Model Tax Convention (the 2014 Update) on 15 July 2014. The 2014 Update was already approved by the Committee on Fiscal Affairs on 26 June 2014.
The 2014 Update can be found here.
The 2014 Update mainly reflects the work that was carried out by the OECD between 2010 and 2013. Next to the amendment of article 26 (Exchange of Information) and its Commentary (the article now explicitly allows for ‘group requests’, i.e. tax authorities are able to ask for information on a group of taxpayers, without naming them individually), it also integrates changes in relation to the following discussion drafts:
- application of Article 17 (Artistes and Sportsmen) of the OECD Model Tax Convention:
- Revised proposals concerning the meaning of “beneficial owner” (released on 19 October 2012)
- Revised discussion draft on tax treaty issues related to emissions permits and credits (released on 19 October 2012)
- Tax treaty treatment of termination payments (released on 25 June 2013)
- Technical changes to be included in the next Update to the Model Tax Convention (released on 15 November 2013).
The 2014 Update to the OECD Model Tax Convention does not yet include the results from the ongoing work of the OECD with regard to the BEPS action plan. These results will be implemented in future updates of the Model Tax Convention.