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The OECD 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 the latest changes to the Model which were approved by the OECD Council on 15 July 2005 (these changes were released in draft form for comments on 15 March 2004); These changes result from work done by the Committee on Fiscal Affairs on a number of issues, in
particular:
- 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 the exchange of information;
- various technical issues related to the interpretation of tax conventions.
The new edition also includes changes made by a number of OECD and non-OECD countries to their observations, reservations or positions on the OECD Model Tax Convention. In addition, Serbia and Montenegro's positions on the Model Tax Convention have been added to the OECD Model Tax Convention.
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