These words appear in neither 2003 OECD Model article 26 nor 2005 OECD Model article 26.

article 5 (1) of the OECD Model TIEA states

However, the OECD Model TIEA provides for an override of any dual criminality requirement. article 5 (1) of the OECD Model TIEA (see para.

OECD issued in 2002 the Model Agreement on Exchange of Information on Tax Matters (hereinafter referred to as OECD Model TIEA), which was developed by the OECD Global Forum Working Group on Effective Exchange of Information and resulted from the work undertaken by OECD to address harmful tax practices beginning with the 1998 OECD report (see OECD Model TIEA, introduction and paras.

However, exchange of information on request is the only method required by (a) UN Model article 26, (b) 2003 OECD article 26, (c) 2005 OECD article 26 and (d) the OECD Model TIEA.

) Therefore, 2003 OECD article 26 and 2005 OECD article 26 provide a broader coverage than UN Model article 26.

Such words also appear in article 1 of the OECD Model TIEA.

The OECD Model TIEA (article 5 (4)) provides in effect for an override in certain instances of bank secrecy and other confidentiality rules (see the Commentary on the OECD Model TIEA, paras.

The same definition appears in article 4 (1) (l) of the OECD Model TIEA.

21 positions on the Commentary to article 5 of the OECD Model Tax Convention).

The relationship between article 5, paragraphs 1 and 3, of the OECD Model Commentary.

3 4, of the OECD Model TIEA. ) It is suggested that the same change be made in UN Model article 26

The counterpart of the United Nations Model Tax Convention, the OECD Model Tax Convention (and its Commentary) was further amended in 2003 and 2005.

It is suggested that, in this regard, UN Model article 26 be modified to reflect the provisions of 2003 OECD article 26 and 2005 OECD article 26.

OECD is currently considering whether in the name of in article 5 (5) of the OECD Model Tax Convention could be interpreted also in an economic sense.

UN Model article 26 is very similar to (but not the same as) 2003 OECD article 26.

2005 OECD article 26 (3) and the suggested revised UN Model article 26 (3) have similar language.

Therefore, in order to determine whether UN Model article 26 should be updated, it is advisable to review the changes in 2003 OECD article 26 made by the OECD Fiscal Committee in issuing 2005 OECD article 26.

(It should be noted that the OECD Model TIEA is only an exchange of information agreement it is not a comprehensive model income tax treaty.

Further, the OECD Fiscal Committee made the following additional changes in 2003 OECD article 26 (1), when it issued 2005 OECD article 26 (and it is suggested that those changes be made in UN Model article 26 (1))

See also OECD, 2005 OECD, 2006.

OECD

In that context, article 5 of the United Nations Model Tax Convention and article 5 of the OECD Model Tax Convention were examined and a comparison was drawn up.

OECD (1998) Adjustment in OECD Agriculture Reforming Farmland Policies.

OECD (2001) Low incomes in agriculture in OECD countries.

Source OECD

OECD, Paris.

Source OECD.

Source OECD.

Analyses of existing model life tables by Coale Demeny, the OECD and the UN have not revealed a universal mortality pattern.

Some of the amendments to the OECD Model Tax Convention, however, include a narrowing of the requirements for constituting a permanent establishment.

GEO, OECD Outlook)

OECD Publications, Paris.

OECD (N 10)

This is OECD.

Therefore, it is recommended that a clause similar to 2005 OECD article 26 (4) be added to UN Model article 26, as follows

OECD, FAO, NAPPO, EPPO

(a) OECD member countries

2. OECD member countries

Adapted from OECD, 2003.

In view of this, it is suggested that the following clause similar to article 5 (1) of the OECD Model TIEA be added to the United Nations Model Income Tax Treaty, as paragraph 26 (6)

Add Regional Environmental Center for Central and Eastern Europe (REC) recommendations OECD OECD references

OECD, Export Credit Financing Systems in OECD Member and Non Member Countries, 2002 Supplement.

OECD, Competition Law and Policy in Russia, an OECD Peer Review, p. 25 (2004).

(d) The addition of paragraph 4.5 to the OECD Commentary should be clarified further in that article 5 (3) of the text of the OECD Model Tax Convention is a special rule under the general rule of article 5 (1)