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Call For Comment - OECD Draft to Changes to Operation of Ships and Aircraft in International Traffic

20 November 2013   (0 Comments)
Posted by: Author: OECD
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Author: OECD

The OECD Committee on Fiscal Affairs (CFA) invites public comments on a discussion draft on proposed changes to the provisions dealing with the operation of ships and aircraft in international traffic. These changes address various issues related to the application of the provisions of the OECD Model Tax Convention applicable to international transport.

These provisions include Article 8, which deals with profits from the operation of ships and aircraft in international traffic and boats engaged in inland waterways transport; paragraph 3 of Article 15, which deals with the taxation of employees who work on such ships, aircraft and boats as well as the definition of the term "international traffic” in subparagraph 3 e) of Article 3 of the Model Tax Convention.

Working Party 1 on Tax Conventions and Related Questions (which is the subgroup of the OECD Committee on Fiscal Affairs in charge of the Model Tax Convention) has undertaken work aimed at reflecting the current treaty practices of the majority of OECD and non-OECD countries concerning Art. 8 and at addressing issues related to the drafting of Art. 15(3). 

This public discussion draft includes proposals for changes to the Model Tax Convention resulting from that work, which primarily concerns international shipping and airline enterprises as well as their employees. Apart from a change proposed to the Introduction, the changes put forward in this discussion draft are not expected to be included in the 2014 Update to the Model Tax Convention.

The Committee therefore invites interested parties to send their comments on this discussion draft before 15 January 2014.  These comments will be examined at the February and September 2014 meetings of the Working Party.

Comments on this discussion draft should be sent in (in Word Format) by e-mail to and should be addressed to:

Tax Treaties, Transfer Pricing and Financial Transactions Division

Unless otherwise requested at the time of submission, comments submitted in response to this invitation will be posted on the OECD website.This document is a discussion draft released for the purpose of inviting comments from interested parties. It does not necessarily reflect the final views of the OECD and its member countries.


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