The document covers a number of issues arising for governments in the administration of bilateral tax treaties connected with employee stock options, such as possible timing mismatches between taxation in the country where the employee resides and the country where s/he has worked. For each issue the document examines the application of the relevant provisions of the OECD Model Tax Convention and proposes possible interpretations and solutions.

Comments should be sent before 31 July 2002 to: jeffrey.owens@oecd.org.

©OECD Observer No 231/232, May 2002