The 1963 OECD Model Tax Convention: Now and Then

Abstract

This article reviews the importance of the 1963 Organization for Economic Co-operation and Development (OECD) Model Tax Convention in the development of the current international bilateral treaties network and compares its principles to those found in the US model tax convention. It then shows how the 1963 OECD model has laid the foundations for the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) agreed on by more than over 100 jurisdictions. US model, OECD model, MLI, tax treaties, international tax, tax history