OECD: Draft changes to model treaty | KPMG | GLOBAL

OECD: Draft changes to model treaty; residence of pension funds

OECD: Draft changes to model treaty

The Organisation for Economic Cooperation and Development (OECD) today issued a release, inviting comments about a discussion draft that includes proposals for changes to the OECD model tax treaty concerning the “treaty residence” of pension funds.


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As noted in the final version of Action 6 under the base erosion and profit shifting (BEP) project, the OECD indicated it would conduct additional work so that a pension fund would be considered to be a resident of the country where it was constituted—regardless whether that pension fund benefits from a limited or complete exemption from tax in that country.


The discussion draft [PDF 264 KB] includes proposed changes to the OECD model tax treaty. Comments are due by 1 April 2016, for consideration at a May 2016 meeting.

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