International juridical double taxation can be generally defined as the imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical periods. Given its harmful effects on the exchange of goods and services and movements of capital, technology and persons, it is important to remove the obstacles that double taxation presents to the development of economic relations between countries.
The member countries of the OECD have long recognised that it is desirable to clarify, standardise, and confirm the fiscal situation of taxpayers who are engaged in commercial, industrial, financial, or any other activities in other countries through the application by all countries of common solutions to identical cases of double taxation. They have also long recognised the need to improve administrative co-operation in tax matters, notably through exchange of information and assistance in collection of taxes, for the purpose of preventing tax evasion and avoidance.
These are the main purposes of the OECD Model Tax Convention on Income and on Capital, which provides a means of settling on a uniform basis the most common problems that arise in the field of international juridical double taxation. The OECD Model requires constant review to address the new tax issues that arise in connection with the evolution of the global economy. The latest edition of the OECD Model (2017) mainly reflects a consolidation of the treaty-related measures resulting from the OECD/G20 BEPS Project.