Updated model treaty

The Organisation for Economic Co-operation and Development has published a new updated version of its Model Tax Convention used by OECD and other countries as a basis for the negotiation application and interpretation of bilateral tax treaties of which there are now more than 2 500 in force around the world.
The model is periodically updated to take account of new developments and to reflect the experience gained by countries in the application of tax conventions. The 2005 edition incorporates changes on a number of issues including:

• the tax treatment of activities related to international shipping and air transport;
• cross-border income tax issues arising from employee stock-option plans;
• tax issues arising from cross-border pensions;
• the issue of multiple permanent establishments;
• the revision of Article 26 and its commentary concerning...