OECD Model Tax Convention on Income and on Capital

The OECD Model Tax Convention on Income and on Capital (OECD Model) and its Commentary provide the basic framework for the global international tax treaty regimes of almost all countries, including transfer pricing rules under Article 9 (Associated Enterprises) of the OECD Model.

The OECD Model Tax Convention includes articles on key international tax concepts such as determining when a multinational enterprise (MNE) has a taxable presence in a country other than the country of its incorporation (permanent establishment), and the dispute resolution (Competent Authority) process for resolving double taxation disputes between treaty countries.