Articles of the OECD Model tax convention on income and on capital (as they read on 29 April 2000)

Articles of the oecd
Model tax convention
On income and on capital

[As they read on 29 April 2000]

SUMMARY OF THE CONVENTION

Title and Preamble

Chapter I

Scope of the Convention

Art. 1 Persons Covered

Art. 2 Taxes covered

Chapter II

Definitions

Art. 3 General definitions

Art. 4 Resident

Art. 5 Permanent establishment

Chapter III

Taxation of income

Art. 6 Income from immovable property

Art. 7 Business profits

Art. 8 Shipping, inland waterways transport and air transport

Art. 9 Associated enterprises

Art. 10 Dividends

Art. 11 Interest

Art. 12 Royalties

Art. 13 Capital gains

Art. 14 [deleted]

Art. 15 Income from employment

Art. 16 Directors’ fees

Art. 17 Artistes and sportsmen

Art. 18 Pensions

Art. 19 Government Service

Art. 20 Students

Art. 21 Other income

Chapter IV

Taxation of capital

Art. 22 Capital

Chapter V

Methods for elimination of double taxation

Art. 23 A Exemption method

Art. 23 B Credit method

Chapter VI

Special provisions

Art. 24 Non-discrimination

Art. 25 Mutual agreement procedure

Art. 26 Exchange of information

Art. 27 Members of diplomatic missions and consular posts

Art. 28 Territorial extension

Chapter VII

Final provisions

Art. 29 Entry into force

Art. 30 Termination

TITLE OF THE CONVENTION

Convention between (State A) and (State B)

with respect to taxes on income and on capital¹

PREAMBLE TO THE CONVENTION²

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¹ States wishing to do so may follow the widespread practice of including in the title a reference to either the avoidance of double taxation or to both the avoidance of double taxation and the prevention of fiscal evasion.

² The Preamble of the Convention shall be drafted in accordance with the constitutional procedure of both Contracting States.

CHAPTER I

SCOPE OF THE CONVENTION

Article 1

PERSONS COVERED

This Convention shall apply to persons who are residents of one or both of the Contracting States.

Article 2

TAXES COVERED

1. This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

2. There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

3. The existing taxes to which the Convention shall apply are in particular:

a) (in State A):..........................................

b) (in State B):..........................................