The draft of the 2008 Model Tax Convention (MTC) was released on 21 April 2008. Details regarding the proposed changes to the Commentary to Art. 12 are reported below.
New additions have been proposed, relating to the definition of royalties. They clarify that payments made in consideration for the transfer of the full ownership of an element of property referred to in the definition of royalties cannot be treated as royalties under Art. 12 of the MTC, as such payment…