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Outcome

Organizational Matters

• Revised tentative programme of work (E/C.18/2008/CRP.9)

Substantive Matters

• Note by the coordinator of the subcommittee on exchange of information: Proposed revised article 26 (exchange of information) and proposed revised commentary (2008) on article 26 (paras. 1-3)* ( and )
• Note by the coordinator of the subcommittee on exchange of information: Proposed revised commentary (2008) on article 26 (paras. 4-6) and proposed code of conduct on cooperation in combating international tax evasion* ( and )
• Treatment of Islamic financial instruments under the United Nations Model Double Taxation Convention between developed and developing countries ( and )

Conference room papers (CRP)

Please note that for logistical reasons we will most likely be able to supply Committee Members only with the larger conference room paper (CRP) documents in Geneva, including the draft Manual for the Negotiation of Bilateral Tax Treaties and documents over 50 pages long. We urge other participants to bring electronic or paper copies of such documents to the Annual Session.

• Note by the coordinator of working group on commentaries of the Ãå±±½ûµØModel Convention: Revision of the commentaries of the Ãå±±½ûµØModel Convention (E/C.18/2008/CRP.1)
• Comments on the Proposal for Amendments of the United Nations Model Double Taxation Convention between Developed and Developing Countries: Further Issues Relating to Permanent Establishment (E/C.18/2008/CRP.1/Add.1)
• Note by the coordinator of the subcommittee on improper use of treaties: Proposed amendments (E/C.18/2008/CRP.2)
• Progress report by the coordinator of the subcommittee on improper use of treaties: Beneficial ownership (E/C.18/2008/CRP.2/Add.1)
• Note by the coordinator of the subcommittee on definition of permanent establishment: Further issues relating to permanent establishment (E/C.18/2008/CRP.3)
• Revision of the United Nations manual for the negotiation of bilateral tax treaties between developed and developing countries (E/C.18/2008/CRP.5, E/C.18/2008/CRP.5/Add.1 and E/C.18/2008/CRP.5/Add.2)

• Presentation

• Resolving issues that prevent a mutual agreement: Supplementary mechanisms for dispute resolution (E/C.18/2008/CRP.6 and E/C.18/2008/CRP.6/Add.1)
• Note by the coordinator of the subcommittee on definition of permanent establishment: Finalised amendments to current commentary on article 5 – permanent establishment (E/C.18/2008/CRP.10)