Tax treaties

OECD Launches Project on Taxation of Collective Investment Vehicles


18 December 2006
An informal consultative group of government and private sector representatives, under the auspices of the OECD’s Centre for Tax Policy and Administration, will tackle the tax treaty issues raised by the large cross-border portfolio investments (more than US$16 trillion) held through collective investment vehicles and global custodians. The project will examine both substantive issues and practical administrative issues related to the application of tax treaties to these investments.


Jeffrey Owens, head of the Centre for Tax Policy and Administration, announced the launch of the project.  “Many, if not most, countries have rules encouraging small investors to use collective investment vehicles to diversify their holdings.  Over 2500 bilateral tax treaties are intended to encourage cross-border investments.  If the two sets of rules don’t work well together, the policies behind both can be frustrated.  We believe the time is ripe to make significant progress in this area, and that the people we are bringing to the table are in the best position to make that happen.”


The project follows up a roundtable that the OECD organized in Paris on 1-2 February 2006 (see  Improving tax treaty benefits for collective investment funds) .Participants to that roundtable suggested that follow-up work by such a group was needed, and a recent joint effort by the OECD Centre for Tax Policy and Administration with BIAC (Business and Industry Advisory Committee to the OECD) concerning the financing of this project has made that possible.


Mr. Robert Waldburger, Head of the Division for International Fiscal Law and Double Taxation Matters (Federal Tax Administration of Switzerland), who chaired the February Roundtable, will also chair the informal consultative group (“CIV ICG”).  Ms. Patricia Brown, most recently Deputy International Tax Counsel (Treaty Affairs) at the U.S. Treasury Department, has been hired by the OECD to provide full-time support for the project. 


The first meeting of the CIV ICG will take place on 9–11 May 2007 in London.
In January, the OECD will also launch an Electronic Discussion Group that will allow all interested parties to be kept informed of the work of the CIV ICG and to provide input into that work.


For further information, please contact Philip Kerfs (


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