OECD Proposes Changes to Model Tax Convention: Treaty Residence of Pension Funds

The OECD explains:

“This discussion draft includes draft changes to Articles 3 and 4 of the OECD Model Tax Convention, and to the Commentary on these Articles, that will ensure that a pension fund is considered to be a resident of the State in which it is constituted for the purposes of tax treaties. These changes were discussed by Working Party 1 on Tax Conventions and Related Questions (which is the subgroup of the OECD Committee on Fiscal Affairs in charge of the Model Tax Convention) at its meeting of February 2016; it was then decided to release the changes for public comments.

Comments should be sent by 1April 2016 at the latest by e-mail to taxtreaties@oecd.org in Word format (in order to facilitate their distribution to government officials). They should be addressed to the Tax Treaties, Transfer Pricing and Financial Transactions Division, OECD/CTPA.  The discussion draft and the comments received will be discussed at the May meeting of Working Party 1.”

The discussion draft is available here.

Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at” drtp.ca
www.drtp.ca

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