For most types of income, especially business profits and investment income, double taxation is avoided in treaties based on the OECD Model Tax Convention by allocating taxing rights between the resident and source countries and by requiring the former to eliminate double taxation where there are competing taxing rights.

Most bilateral tax treaties follow both the principles and the detailed provisions of the OECD Model. There are close to 350 treaties between OECD Member countries and over 1500 world-wide which are based on the Model, and it has had considerable influence on the bilateral treaties between non-member countries.

As a sign of that influence, the Working Party on Tax Conventions and Related Issues has regular contact with non-OECD members to discuss developments in the Model and problems of application and interpretation of bilateral treaties.

As part of its regular work, the Working Party is currently deliberating a number of issues, which could result in further changes to the Model and the Commentary thereon.