אמנת המודל של ה-OECD (המשך)
מיסוי בינלאומי -
ARTICLES OF THE OECD MODEL CONVENTION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL
[as they read on 28 January 2003]
SUMMARY OF THE CONVENTION
TITLE AND PREAMBLE
Scope of the Convention
Art. 1 Persons Covered
Art. 2 Taxes covered
TITLE OF THE CONVENTION
Convention between (State A) and (State B)
with respect to taxes on income and on capital
PREAMBLE TO THE CONVENTION
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. The Preamble of the Convention shall be drafted in accordance with the constitutional procedure of both Contracting States.
SCOPE OF THE CONVENTION
This Convention shall apply to persons who are residents of one or both of the Contracting States.
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.
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.
The existing taxes to which the Convention shall apply are in particular:
a) (in State A): ..........................................
b) (in State B): ..........................................
The Convention shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in their taxation laws.