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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.

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Commentary on Article 29

As explained in the footnote to the Article, Article 29 reflects the intention of the Contracting States, incorporated in the preamble of the Convention, to eliminate double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treatyshopping arrangements. This intention and the wording of the Article correspond to the minimum standard that was agreed to as part of the OECD/G20 Base Erosion and Profit Shifting Project and that is described in paragraph 22 of the report Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report.

English

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