Commentary on Article 1: Concerning the Persons Covered by the Convention |
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Commentary on Article 2: Concerning Taxes Covered by the Convention |
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Commentary on Article 3: Concerning General Definitions |
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Commentary on Article 4: Concerning the Definition of Resident |
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Commentary on Article 5: Concerning the Definition of Permanent Establishment |
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Commentary on Article 6: Concerning the Taxation of Income From Immovable Property |
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Commentary on Article 7: Concerning the Taxation of Business Profits |
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Commentary on Article 8: Concerning the Taxation of Profits From International Shipping
and Air Transport
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Commentary on Article 9: Concerning the Taxation of Associated Enterprises |
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Commentary on Article 10: Concerning the Taxation of Dividends |
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Commentary on Article 11: Concerning the Taxation of Interest |
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Commentary on Article 12: Concerning the Taxation of Royalties |
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Commentary on Article 13: Concerning the Taxation of Capital Gains |
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Commentary on Article 14: Concerning the Taxation of Independent Personal Services |
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Commentary on Article 15: Concerning the Taxation of Income From Employment |
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Commentary on Article 16: Concerning the Taxation of Directors’ Fees |
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Commentary on Article 17: Concerning the Taxation of Entertainers and Sportspersons |
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Commentary on Article 18: Concerning the Taxation of Pensions |
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Commentary on Article 19: Concerning the Taxation of Remuneration in Respect of Government
Service
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Commentary on Article 20: Concerning the Taxation of Students |
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Commentary on Article 21: Concerning the Taxation of Other Income |
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Commentary on Article 22: Concerning the Taxation of Capital |
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Commentary on Article 23 A. and 23 B.: Concerning the Methods for Elimination of Double
Taxation
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Commentary on Article 24: Concerning Non-Discrimination |
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Commentary on Article 25: Concerning the Mutual Agreement Procedure |
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Commentary on Article 26: Concerning the Exchange of Information |
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Commentary on Article 27: Concerning the Assistance in the Collection of Taxes |
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Commentary on Article 28: Concerning Members of Diplomatic Missions and Consular Posts |
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Commentary on Article 29: Concerning the Entitlement to benefits |
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Commentary on Article 30: Concerning the Territorial Extension of the Convention |
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Commentary on Article 31 and 32: Concerning the Entry Into force and the Termination
of the Convention
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