The Organisation for Economic Cooperation and Development (OECD) on Thursday 25 April 2019, published the full version of its 2017 Model Tax Convention on Income and Capital, the tenth edition.

This full version contains Articles, Commentaries, non-member economies' positions, the Recommendation of the OECD Council, the historical notes and the background reports. It incorporates some of the measures from the OECD BEPS Project including hybrid mismatch, treaty shopping, artificial avoidance of permanent establishment and dispute resolution.

The model convention is designed to provide a standard template for concluding avoidance of double taxation treaties between countries to facilitate economic development, limit double taxation, prevent double non-taxation, and enhance mutual agreements and assistance on tax matters.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.