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MODEL TAX CONVENTION: ELECTRONIC VERSION 2008 to be Released Fall 2008.
Content Description | Features of Electronic Version | Using eMTC | How to Obtain eMTC
CONTENT
The OECD Model Convention on Income and on Capital (MTC) serves as a model used by countries when negotiating bilateral tax agreements. These agreements are entered into by countries to clarify the situation when a taxpayer might find himself subject to taxation in more than one country. The Convention is dynamic in that it is constantly monitored and updated as economies evolve and new tax questions arise. In recent years, for example, special reports have had to be done on tax treatment of software and treaty characterization issues arising from e-commerce.
The Convention consists of Articles, Commentaries on the Articles which include OECD member country Reservations, Histories of the Articles, Non-Member Country Positions on the Articles, and Special Reports related to the Convention. This model is used not only by country officials negotiating bilateral tax treaties, but also by lawyers and accountants having to interpret these treaties for their clients. An update is scheduled to appear in the Fall of 2008 and will include the updates approved by the OECD Council on July 17, 2008. It will also include multiple-window view, enabling users to look at, for example, an article and its commentaries at the same time.
FEATURES OF THE 2008 ELECTRONIC VERSION (eMTC)
The 2008 Electronic Version of the OECD Model Tax Convention will be offered in several ways:
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The eMTC Set that includes: 1) the downloadable version for local use that includes the "Notes" feature and the multiple window feature and that can be downloaded immediately, 2) a USB Memory Stick with the eMTC preloaded--benefit is that it can be moved from machine to machine, and 3) copy of the condensed version of the book.
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eMTC Downloadable that includes the "Notes" and multiple windows features but does not include a copy of the book or a copy of the memory stick. The downloadable version is good for one installation only and is tied to the machine on which it is installed. This version will also be made available on SourceOECD to users at institutions subscribing to SourceOECD/Books and SourceOECD/Taxation.
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An eMTC Online Version will be offered on SourceOECD to SourceOECD/Books and SourceOECD/Taxation Subscribers later in 2008. It will not have the "Notes" or multiple windows features and navigation will not be as fast as with the downloadable version, but will not require users to download and install.
The 2008 electronic versions of the MTC (eMTC), prepared in co-operation with Eurofield Information Systems, is based on the text as it was updated on 17 July 2008, and includes some related elements not included in the loose-leaf version including the texts of the 1963 and 1977 Conventions. The electronic version also includes numerous features that will make working with the convention much easier including extensive internal linking.
Because the eMTC includes software that enables users to append notes to segments of Convention text; to navigate between Articles, Commentaries, History, and Country Positions; and to rapidly search the full text for terms and phrases, it is sold either on a USB Memory Stick or as a downloadable, executable file. On SourceOECD, it is included as a part of subscriptions to SourceOECD/Books and SourceOECD/Taxation. Everytime the installed file is executed from a local PC that is connected to the internet, the programe checks to see if it is the latest version available and if not, the users is informed.
The electronic version of MTC includes the following powerful features:
- Using the local versions (downloadable or memory stick), Users can append their own notes to specific paragraphs in the text of the Convention. Users can exchange their notes with other users. All notes are automatically transcribed in context into updated versions of the eMTC.
- Users can quickly do full-text searches for particular terms or phrases using the drag-on icon and the search tools. With every word, number, and alphanumeric indexed, users can search for absolutely everything within the publication. Hits are highlighted in the text.
- Users can easily navigate between Articles, Commentary, History, Country Positions, and Related Reports through the table of contents and extensive internal linking.
- For the first time, in the 2008 local versions, users can open up to four windows, enabling them to view an Article and its related Commentary, Country Positions and Histories at the same time.
- In the histories, text from previous versions of the Convention is highlighted in blue, to distinguish it from the current version. This is important in cases where the action in question took place at a time when a previous version of the Convention was in force.
- Users can cut and paste or ‘drag and drop’ from the text with all formatting remaining preserved.
- The program is highly compressed, so it does not take up much space on a hard drive.
- Users can print from the text.
USING eMTC
When purchasing eMTC from the OECD Online Bookshop, users either download and install the executable file or wait to receive the memory stick. The program runs from the memory stick, which can be used on any computer. Any notes created by users using the locally installed version are placed in a file on the C drive. Users using the memory stick will have the notes stored on the memory stick. Users wanting to share notes with other eMTC can do so by providing their notes files to the other users. Users at institutions subscribing to SourceOECD/Books or SourceOECD/Taxation can either view the online version that does not have the notes and mutliple windows feature, or download and install the local version - which has the notes feature and runs much faster.
Whenever the local version is opened on a machine with internet access, the program checks to see if the version being used is the latast available and if not, the user is notified. The version on SourceOECD will always be the most up to date available.
When opening eMTC, the follow screen appears (screen shots feature the 2005 text):
The Table of Contents appears on the left column and can be expanded or pruned as the user desires. At all times the Table of Contents will stay synchronized with text of the publication so the user can never get lost. The user instructions appear in the “Navigation Quick Start” box, which can be moved around the screen or minimized.
If the program is closed, clicking on the drag-on icon will open the program. If the program is open, Dragging a term or phrase onto the icon will result in a full-text search of the Convention for the desired term or phrase. The drag-on icon can be turned on or off and its size can be adjusted.
Scroll the Title Page for the copyright notice and a more detailed Table of Contents
The icons across the top of the screen allow for returning to the home Table of Contents, Backtracking, Pruning the Table of Contents, various Search functions, appending/moving/deleting of personal notes, cutting/copying/pasting, printing, and adjusting the text size on the screen. Click on “Help” for more detailed usage instructions.
When you open an article, you see the following:
Notice that when in an article, links are provided to the related commentary and history. Links are also available for footnotes.
When you open a commentary, you see:
Notice that from a commentary, you can link back to the text of the article in question and to related articles and reports. Text highlighted in blue is text as it appeared in a previous version of the Convention. Similar navigation and text identification appears in the country positions pages.
The 2008 edition features the ability to open multiple windows simultaneously, enabling the user to show, for example, an article along with its related commentary, country positions, and history all at the same time:
In addition to the Articles, Commentaries, and Country Positions, the eMTC also includes the following related reports. The 2008 edition will have several new ones added as well as a new report on Attribution of Profits. When mentioned within commentaries to articles, links to these reports are provided.
- R1. Transfer pricing, corresponding adjustments and the mutual agreement procedure
- R2. The taxation of income derived from the leasing of industrial, commercial or scientific equipment
- R3. The taxation of income derived from the leasing of containers<>/li>
- R4. Thin capitalisation
- R5. Double taxation conventions and the use of base companies
- R6. Double taxation conventions and the use of conduit companies R7. The taxation of income derived from entertainment, artistic and sporting activities
- R8. Tax treaty override
- R9. The 183 day rule: some problems of application and interpretation
- R10. The tax treatment of software
- R11. Triangular cases
- R12. The tax treatment of employee's contributions to foreign pension schemes
- R13. Attribution of income to permanent establishments
- R14. Tax sparing
- R15. The application of the OECD model tax convention to partnerships
- R16. Issues related to article 14 of the model tax convention
- R17. Restricting the entitlement to treaty benefits
- R18. Treaty characterisation issues arising from e-commerce
- R19. Issues arising under article 5 (permanent establishment) of the model tax convention
The eMTC also includes the Recommendation of the OECD Council related to the MTC and the texts of the 1963 and 1977 model conventions. There is also a table listing, for each OECD country, countries with whom it has concluded bilateral conventions based on the MTC.
This new tool is also available in French. The most recent update to the MTC was approved by the OECD Council on July 17, 2008. The Condensed Print version in English is being released early in September of 2008 and the the English eMTC version is expected in November 2008. French versions will follow.
HOW TO GET THE OECD MODEL TAX CONVENTION: ELECTRONIC VERSION
If your institution subscribes to SourceOECD/Books or SourceOECD/Taxation, you'll be able to access eMTC at: http://www.SourceOECD.org/references. See the list of subscribing institutions at: http://www.oecd.org/dataoecd/53/31/34262067.doc
The OECD Model Tax Convention: Electronic Version 2008 on USB Memory Stick is also available on the OECD Online Bookshop .
Or, order through a local distributor:
at:http://www.oecd.org/publishing/distributors
If you are with a organization that could use multiple copies of the OECD Model Tax Convention: Electronic Version, we suggest you subscribe to SourceOECD/Taxation. This will give you online access to not only to the Model Tax Convention downloads, but also to PDF files of all OECD publications on taxation published since 1998. The 2008 subscription to SourceOECD/Taxation, Print + Online is priced at: €951, $1225, £654, ¥134,700. Print + Online includes one copy of each new print publications released in the Taxation category during the subscription year. The 2008 subscription to SourceOECD/Taxation Online Only is priced at €650, $838, £447, ¥94,200.
To licence the MTC for intranets, consult our licensing manager: James.Kitchen@oecd.org
OECD Publishing
Public Affairs and Communications Directorate
2 rue Andre-Pascal
75016 Paris Cedex 16
France
Tel +33 (0) 1 45 24 81 67
Fax +33 (0) 1 45 24 19 50
sales@oecd.org
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