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

Par Robert Robillard - 1 mars 2016

This blogpost originally appeared on rbrt.ca.

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 April 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, Adm.A., MBA, M.Sc. Econ., M.A.P.
Senior Partner, RBRT Inc.
514-742-8086; robertrobillard « at » rbrt.ca
www.rbrt.ca

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