KPMG report: Comments on proposed changes to Commentaries in OECD Model Tax Convention, Article 9 and related articles

KPMG tax professionals have responded to the OECD request for comments.

KPMG tax professionals have responded to the OECD request for comments.

The Organisation for Economic Cooperation and Development (OECD) in a 29 March 2021 consultation document described proposed changes to the Commentaries in the OECD Model Tax Convention with respect to Article 9 and related articles.

As noted in an OECD release (March 2021), Article 9 of the OECD Model Tax Convention deals with the tax treatment of transactions between associated enterprises or related parties. The OECD’s efforts to revise the Commentaries to the Model Tax Convention would be intended to reflect updates to the OECD Transfer Pricing Guidelines to supplement the Commentary on Article 9 by providing detailed guidance on the application of the arm’s length principle.

KPMG tax professionals have responded to the OECD request for comments. Read the KPMG comments (May 2021) [PDF 160 KB]


The OECD on 3 June 2021 released a compendium of comments. According to the OECD release, all comments received are in a large “zip file” [PDF 10 MB].

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