By OECD. Published by : OECD Publishing
This e-book is the 6th variation of the Condensed model of the OECD version Tax conference on source of revenue and Capital. This shorter model comprises the entire textual content of the Articles, remark, and state Positions of the version Tax Conve
Read Online or Download Model Tax Convention on Income and on Capital Model Tax Convention on Income and on Capital: Condensed version -- July 2005 PDF
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Additional resources for Model Tax Convention on Income and on Capital Model Tax Convention on Income and on Capital: Condensed version -- July 2005
The provisions of paragraph 1 shall not apply to income derived or capital owned by a resident of a Contracting State where the other Contracting State applies the provisions of the Convention to exempt such income or capital from tax or applies the provisions of paragraph 2 of Article 10 or 11 to such income. Article 23 B CREDIT METHOD 1. Where a resident of a Contracting State derives income or owns capital which, in accordance with the provisions of this Convention, may be taxed in the other Contracting State, the first-mentioned State shall allow: a) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in that other State; 38 ¤ OECD MODEL CONVENTION b) as a deduction from the tax on the capital of that resident, an amount equal to the capital tax paid in that other State.
2. Where in accordance with any provision of the Convention income derived or capital owned by a resident of a Contracting State is exempt from tax in that State, such State may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. CHAPTER VI SPECIAL PROVISIONS Article 24 NON-DISCRIMINATION 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected.
Some states may wish to include in their conventions a provision that expressly confirms a Contracting State’s right to tax resident partners on their share of the income of a partnership that is treated as a resident of the other State. 2 Another issue is that of the effect of the provisions of the Convention on a Contracting State’s right to tax income arising on its territory where the entitlement to the benefits of one, or more than one, Conventions is different for the partners and the partnership.