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
CHAPTER I
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
1
PREAMBLE TO THE CONVENTION
2
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.
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):
..........................................
4.
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.
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