The OECD 2008 Update to the Model Tax Convention (with India’s position)

The OECD 2008 Update to the Model Tax Convention incorporating India’s position , as approved by the Committee on Fiscal Affairs at its meeting of 24-25 June 2008 and the OECD Council on 17 July 2008 can be downloaded here (1.2 MB).

The contents of the 2008 update result primarily from the following reports:

Improving the Resolution of Tax Treaty Disputes That report was adopted by the Committee on Fiscal Affairs on 30 January 2007 following extensive consultations that included the release of a discussion draft on 1 February 2006 and a public consultation meeting in Tokyo on 13 March 2006.

Revised Commentary on Article 7. The revised Commentary on Article 7 was first released as a public discussion draft on 10 April 2007. In accordance with earlier decisions by the Committee concerning the implementation of the conclusions from its work on Attribution of Profits to Permanent Establishments, the revised Commentary incorporates those aspects of the conclusions from that work that do not conflict with the existing interpretation of Article 7 reflected in the current version of the Commentary (the Committee has also approved, on 25 June 2008, the public release of the second part of the implementation package, i.e. a new Article 7 and related Commentary changes that will fully incorporate the conclusions of the Report on Attribution of Profits to Permanent Establishments).

For more details, please visit OECD.