INTM159013 - OECD Model Tax Convention - Introduction

United Nations Model

In 1979, the United Nations published a draft model agreement for use between developed and less developed countries. It is updated periodically, although not as often as the OECD model. A major difference between the OECD and the United Nations model agreements is that the latter preserves more of the taxing rights of the country in which income arises (the 'Source State') which tends to favour less developed countries.

The United Nations model has not been reproduced in this guidance as it is not relied on for guidance in the same way as the OECD model and Commentary. Any enquiries concerning it should be referred to Revenue Policy, International, External Relations Group (Advisory).