Model Tax Convention on Income and on Capital: Condensed Version 2017
This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the articles and commentaries of the Model Tax Convention on Income and Capital as it read on 21 November 2017, but without the historical notes and the background reports that are included in the full version.
- Click to access:
-
Click to download PDF - 3.13MBPDF
Commentary on Article 9
This Article deals with adjustments to profits that may be made for tax purposes where transactions have been entered into between associated enterprises (parent and subsidiary companies and companies under common control) on other than arm’s length terms. The Committee has spent considerable time and effort (and continues to do so) examining the conditions for the application of this Article, its consequences and the various methodologies which may be applied to adjust profits where transactions have been entered into on other than arm’s length terms. Its conclusions are set out in the report entitled Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations,1 which is periodically updated to reflect the progress of the work of the Committee in this area. That report represents internationally agreed principles and provides guidelines for the application of the arm’s length principle of which the Article is the authoritative statement.
Also available in: French
- Click to access:
-
Click to download PDF - 223.35KBPDF