Granting Tax Treaty Benefits to Collective Investment Vehicles: A Review of the OECD Report and the 2010 Amendments to the Model Tax Convention

Abstract

One of the significant amendments to the 2010 Model Tax Convention is the introduction of new paragraphs to Article 1 of the Commentary regarding the granting of tax treaty benefits to Collective Investment Vehicles (CIVs). Those amendments are the result of the work performed by the Organisation for Economic Co-operation and Development (OECD) in the past years, which gave rise to a report, published in April 2010. This article describes the contents of this report and the corresponding amendments to the Commentary and, where relevant, makes some critical remarks to the solutions provided therein.