All the United Kingdom's agreements entered into since the
publication of the first OECD model have been based on successive
updates of it with appropriate variations to take into account,
where necessary, the differing economic circumstances and tax and
legal systems of the two countries.
There are still in force a small number of agreements, mainly
with the United Kingdom's former colonies, which were entered into
before the OECD model was published. Their provisions can differ
radically from modern treaties and the OECD Commentary will not
necessarily be a guide to their interpretation.
