OECD Model Tax Convention Commentary

Contents

Commentary on Article 1 - Concerning the Persons Covered by the Convention

Commentary on Article 2 - Concerning Taxes Covered by the Convention

Commentary on Article 3 - Concerning General Definitions

Commentary on Article 4 - Concerning the Definition of Resident

Commentary on Article 5 - Concerning the Definition of Permanent Establishment

Commentary on Article 6 - Concerning the Taxation of Income from Immovable Property

Commentary on Article 7 - Concerning the Taxation of Business Profits

Commentary on Article 8 - Concerning the Taxation of Profits from International Shipping and Air Transport

Commentary on Article 9 - Concerning the Taxation of Associated Enterprises

Commentary on Article 10 - Concerning the Taxation of Dividends

Commentary on Article 11 - Concerning the Taxation of Interest

Commentary on Article 12 - Concerning the Taxation of Royalties

Commentary on Article 13 - Concerning the Taxation of Capital Gains

Commentary on Article 14 - Concerning the Taxation of Independent Personal Services

Commentary on Article 15 - Concerning the Taxation of Income from Employment

Commentary on Article 16 - Concerning the Taxation of Directors' Fees

Commentary on Article 17 - Concerning the Taxation of Entertainers and Sportspersons

Commentary on Article 18 - Concerning the Taxation of Pensions

Commentary on Article 19 - Concerning the Taxation of Remuneration in Respect of Government Service

Commentary on Article 20 - Concerning the Taxation of Students

Commentary on Article 21 - Concerning the Taxation of Other Income

Commentary on Article 22 - Concerning the Taxation of Capital

Commentary on Articles 23 A and 23 B - Concerning the Methods for Elimination of Double Taxation

Commentary on Article 24 - Concerning Non-Discrimination

Commentary on Article 25 - Concerning the Mutual Agreement Procedure

Commentary on Article 26 - Concerning the Exchange of Information

Commentary on Article 27 - Concerning the Assistance in the Collection of Taxes

Commentary on Article 28 - Concerning Members of Diplomatic Missions and Consular Posts

Commentary on Article 29 - Concerning the Entitlement to Benefits

Commentary on Article 30 - Concerning the Territorial Extension of the Convention

Commentary on Articles 31 and 32 - Concerning the Entry into Force and the Termination of the Convention