10 February 2010 - On 25 November 2009, the OECD Committee on Fiscal Affairs released for public comments the draft of a Report which contains proposed changes to the Commentary on the OECD Model Tax Convention dealing with the application of tax treaties to state-owned entities, including Sovereign Wealth Funds. The Committee is considering the inclusion of these changes in the next update to the OECD Model Tax Convention, which is tentatively scheduled for the second part of 2010. The OECD has now published the comments received on this consultation draft, which can be downloaded by clicking on the links below:

• Abu Dhabi Investment Authority (“ADIA”)
• Institute of Chartered Accountants in England and Wales (ICAEW)
• KPMG
• PricewaterhouseCoopers Services LLP (“PwC”)
• TAXAND