OECD Ponders Changes to Model Tax Treaty Commentaries

March 29, 2021, 2:31 PM

The Organization for Economic Cooperation and Development launched a consultation Monday to update its model tax treaty commentaries.

The commentaries sit alongside the model treaty and suggest how countries should interpret and apply treaties.

  • Among the proposed updates are new wording in sections covering interest deductibility, dispute resolution and business profits.
  • The changes are linked to February guidance the OECD published on transfer pricing for financial transactions. That guidance outlined the organization’s position on how intra-company financial transactions prices should be treated for tax purposes.
  • The consultation period runs until May 28.

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