22/01/2024 - On 16 November 2023, the OECD invited public comments on the proposed changes to the Commentary on Article 5 of the OECD Model Tax Convention and its application to extractible natural resources.

 

These proposed changes result from the work by Working Party 1 on Tax Conventions and Related Questions - which is the subgroup of the OECD Committee on Fiscal Affairs in charge of the OECD Model Tax Convention - with a view to developing an alternative provision for inclusion in the Commentary on Article 5 of the OECD Model Tax Convention on activities in connection with the exploration and exploitation of extractible natural resources, together with related commentary.

 

The OECD is grateful to the commentators for their input and now publishes the public comments received.

 

• Download the comments (Zip file, 2.06 MB - Please open from a desktop computer)

 

For more information on the OECD's public consultations on tax matters, visit https://oe.cd/tax-input.

 

Enquiries should be addressed to taxtreaties@oecd.org.