Feb 2010 The OECD has recently published proposals for the granting of tax treaty benefits to funds. The proposals will form part of the commentary on the OECD Model Tax Convention, a revised version of which is due for publication later this year. A Pilot Group of industry representatives and OECD country members was set up to consider the practical implications and to propose measures to improve international withholding and investor reporting procedures. The Pilot Group has now almost completed its work and the OECD is expected to release a draft implementation package for public comment in the next few months. This will include a model memorandum of understanding and generic documentation and contracts. It is intended that the proposed procedures will cover all intermediaries, not just funds.
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Tax Bulletin - Tax treaty benefits for funds: OECD proposals (Feb 2010) (pdf file, 45KB) for your reference.