The explanation on the 2017 OECD Model Tax Convention was edited to enhance the understanding of readers only on parts that need a clear understanding. The explanation data are to be published on BEPS International's bulletin board over a long period of time.
The revised contents were highlighted in blue to distinguish the existing contents from the parts which were newly revised in 2017.
With the introduction of the BEPS project, multinationals are required to submit BEPS reports to tax authorities in each country, and therefore understanding the global level tax treaty (the 2017 OECD Model Taxation Convention) has become essential.
Currently, it would be very difficult to understand the global-level tax treaties only with an understanding of tax treaties signed between Korea and other countries. For example, without the exact understanding of provisions such as the "Entitlement to Benefit".
In case where Korean multinational companies enter the U.S. or Britain to do business and engage in international transactions with the companies of European countries, they must understand the tax treaties signed between the U.S. or Britain and European countries to properly conduct international transactions and prepare BEPS reports. Therefore, the explanation on the 2017 OECD Model Tax Convention will be carried out in consideration of this.