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Model Tax Convention on Income and on Capital: Condensed Version 2017

image of Model Tax Convention on Income and on Capital: Condensed Version 2017

This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the articles and commentaries of the Model Tax Convention on Income and Capital as it read on 21 November 2017, but without the historical notes and the background reports that are included in the full version.

The full version of the OECD Model Tax Convention for each edition is published separately. It is available in print, PDF and web formats. The web format includes extensive interlinking, making it easy to link from articles to related commentaries. The web and PDF versions will be available via the OECD iLibrary.

English

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Commentary on Article 1

Whereas many conventions concluded in the first part of the 20th century were applicable to “citizens” of the Contracting States, conventions concluded afterwards almost always apply to “residents” of one or both of the Contracting States irrespective of nationality. That approach is reflected in paragraph 1. The term “resident” is defined in Article 4. The fact that a person is a resident of a Contracting State does not mean, however, that the person is automatically entitled to the benefits of the Convention since some or all of these benefits may be denied under various provisions of the Convention, including those of Article 29.

English

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