Study Of The Oecd Model Tax Convention Updates And A Number Of Hot Issues

Since the establishment of OECD, it has made enormous contribution to the lasting growth of global economy. Having released its first model tax convention since 1963, OECD even releases the updated edition of its model in one year or several years now. From 1992, the model is released in a loose-leaf format in order to include the new change constantly. The revised model of 1997, which has adopted a lot of suggestions of non-member states, was more suitable for China. Our country always pays attention to research the domestic tax law; meanwhile, research on tax treaty seems rather limited. After entering WTO, the flow of personnel and capital become strengthen further, the requirement to study on international tax treaty become more urgent. OECD model, because of its timely update, its ability to meet and solve various kinds of problem which arising from economic globalization, have already become the main reference text that most countries refer to when they sign the tax treaty now. This model has been in leading position all the time about the research in such problems as e-commerce, stock option, etc. These new problems are appearing constantly too after our country's entering WTO. So, not only to comply with the international practice but also to protect our country's own sovereignty and interests, researching the development course, upgrade characteristic and hot problem of OECD model will have certain guidance and reference meaning to the work on tax treaty in our country.This thesis not only review the historical evolution progress of OECD model tax convention, but also explain some hot problems which are the key work that engaged in now. I hope that we can understand its unity of history and era more deeply. The thesis is divided into four parts:First part: the origin of the international tax treaty and its standardized development. I have explained the process of origin of the international tax treaty and two models (OECD model and UN model), and have mainly described the historical evolution of OECD model especially.Second part: update of the content of OECD model since 1992.1 have explained the changes of the revised model and commentary since 1992, also the updated characteristic.The third part: several hot problems of the revised model. This part is a focal part of this thesis; mainly discussed some hot issues that OECD is studied. I have separately discussed the changes of update and current rule in permanent establishment, e-commerce, stock option, assistance in collection, etc.The fourth part: the inspiration for our country to do research on OECD model. Combine our country's national conditions, I discussed if OECD model is suitable for our country, and proposed some suggestions of the following work in practice.