On 29 February 2016, the OECD published a discussion draft on changes to Articles 3 (General Definitions) and 4 (Resident) of the OECD Model Tax Convention and the associated commentary concerning the tax residence of pension funds. The changes were included as a next step in the final report for Action 6 of the OECD BEPS Project (Preventing the Granting of Treaty Benefits in Inappropriate Circ…