Last updated 2026-06-27

OECD Model Tax Convention

The OECD Model Tax Convention is the international standard framework used as the basis for most bilateral tax treaties. Article 10 governs dividend withholding tax: it sets a 15% standard rate for portfolio investors and 5% for substantial shareholders (holding ≥25% of voting shares). Over 3,000 bilateral treaties worldwide follow this model.

The OECD Model Convention is updated periodically — the most recent version was 2017, with commentary updates through 2023. Countries negotiate deviations from the model: for example, some Nordic–Nordic treaties set 0% on dividends. The US uses its own Model Treaty which is broadly similar but differs on treaty shopping provisions and LOB (Limitation on Benefits) clauses.

Source: OECD Model Tax Convention on Income and on Capital, Full Version 2017