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

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

作者： OECD
出版商： OECD Publishing
ISBN: 9789264287945
出版时间 February 2018
规格： Paperback , 496 pages
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

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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 Covention on Income and Capital as it read on 21 November 2017, but without the historical notes and the background reports included in the full version.
Introduction 7
Model Convention with respect to Taxes on Income and on Capital (Articles)19
Commentaries on the Articles of the Model Tax Convention 45
-Commentary on Article 1 (Persons covered) 47
-Commentary on Article 2 (Taxes covered)   77
-Commentary on Article 3 (General definitions) 80
-Commentary on Article 4 (Resident) 85
-Commentary on Article 5 (Permanent establishment) 94
-Commentary on Article 6 (Income from immovable property) 130
-Commentary on Article 7 (Business profits) 132
-Commentary on Article 8 (Shipping, inland waters transport and air transport) 176
-Commentary on Article 9 (Associated enterprises) 183
-Commentary on Article 10 (Dividends) 187
-Commentary on Article 11 (Interest) 208
-Commentary on Article 12 (Royalties) 224
-Commentary on Article 13 (Capital gains)  243
-Commentary on Article 14 [Deleted] 255
-Commentary on Article 15 (Income from employment) 256
-Commentary on Article 16 (Director's fees) 279
-Commentary on Article 17 (Entertainers and sportspersons)  281
-Commentary on Article 18 (Pensions) 292
-Commentary on Article 19 (Government service) 310
-Commentary on Article 20 (Students) 315
-Commentary on Article 21 (Other income) 316
-Commentary on Article 22 (Capital) 320
-Commentary on Articles 23 A and 23 B (Exemption and credit methods for eliminating double taxation) 323
-Commentary on Article 24 (Non-discrimination) 349
-Commentary on Article 25 (Mutual agreement procedure) 371
-Commentary on Article 26 (Exchange of Information) 414
-Commentary on Article 27 (Assistance in collection of taxes) 434
-Commentary on Article 28 (Members of diplomatic missions and consular posts) 443
-Commentary on Article 29 (Territorial extension) 445
-Commentary on Articles 30 and 31 (Entry into force and termination) 446
Non-OECD economies’ positions on the OECD Model Tax Convention  447
Annex – Recommendation of the OECD Council concerning the Model Tax Convention on Income and on Capital  491

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