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By Oliver R. Hoor *
On 15 July 2014, the OECD approved the 2014 update to the OECD Model Tax Convention (the “2014 Update”). This update includes changes to Article 26 (Exchange of Information) and its Commentary, additional guidance on the meaning of “beneficial owner” for tax treaty purposes and changes to the Commentary on Article 17 (Entertainers and Sportsmen). It further provides for new guidance regarding tax treaty issues related to emissions permits/credits and the tax treaty treatment of termination payments. Finally, the 2014 Update introduces a number of mere technical changes. The most important elements of the 2014 Update are outlined in the present article.
I. Introduction
Most tax treaties worldwide including those...
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