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1、wordMODEL CONVENTIONWITH RESPECT TO TAXESON INE AND ON CAPITALTITLE AND PREAMBLECHAPTER IScope of the ConventionArt. 1 Persons CoveredArt. 2 Taxes coveredCHAPTER IIDefinitionsArt. 3 General definitionsArt. 4 ResidentArt. 5 Permanent establishmentCHAPTER IIITaxation of ineArt. 6 Ine from immovable pr
2、opertyArt. 7 Business profitsArt. 8 Shipping, inland waterways transport and air transportArt. 9 Associated enterprisesArt. 10 DividendsArt. 11 InterestArt. 12 RoyaltiesArt. 13 Capital gainsArt. 14 DeletedArt. 15 Ine from employmentArt. 16 Directors feesArt. 17 Artistes and sportsmenArt. 18 Pensions
3、Art. 19 Government ServiceArt. 20 StudentsArt. 21 Other ineCHAPTER IVTaxation of capitalArt. 22 CapitalCHAPTER VMethods for elimination of double taxationArt. 23 A Exemption methodArt. 23 B Credit methodCHAPTER VISpecial provisionsArt. 24 Non-discriminationArt. 25 Mutual agreement procedureArt. 26 E
4、xchange of informationArt. 27 Assistance in the collection of taxesArt. 28 Members of diplomatic missions and consular postsArt. 29 Territorial extensionCHAPTER VIIFinal provisionsArt. 30 Entry into forceArt. 31 TerminationTITLE OF THE CONVENTIONConvention between (State A) and (State B)with respect
5、 to taxes on ine and on capital1PREAMBLE TO THE CONVENTION21. States wishing to do so may follow the widespread practice of including in the title areference to either the avoidance of double taxation or to both the avoidance of doubletaxation and the prevention of fiscal evasion.2. The Preamble of
6、the Convention shall be drafted in accordance with the constitutionalprocedure of both Contracting States.CHAPTER ISCOPE OF THE CONVENTIONArticle 1PERSONS COVEREDThis Convention shall apply to persons who are residents of one or both of theContracting States.Article 2TAXES COVERED1. This Convention
7、shall apply to taxes on ine and on capital imposed on behalfof a Contracting State or of its political subdivisions or local authorities, irrespective of themanner in which they are levied.2. There shall be regarded as taxes on ine and on capital all taxes imposed ontotal ine, on total capital, or o
8、n elements of ine or of capital, including taxes ongains from the alienation of movable or immovable property, taxes on the total amounts ofwages 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) (
9、in State A): .b) (in State B): .4. The Convention shall apply also to any identical or substantially similar taxes thatare imposed after the date of signature of the Convention in addition to, or in place of,the existing taxes. The petent authorities of the Contracting States shall notify eachother
10、of any significant changes that have been made in their taxation laws.CHAPTER IIDEFINITIONSArticle 3GENERAL DEFINITIONS1. For the purposes of this Convention, unless the context otherwise requires:a) the term person includes an individual, a pany and any other body ofpersons;b) the term pany means a
11、ny body corporate or any entity that is treated as abody corporate for tax purposes;c) the term enterprise applies to the carrying on of any business;d) the terms enterprise of a Contracting State and enterprise of the other ContractingState mean respectively an enterprise carried on by a resident o
12、f a ContractingState and an enterprise carried on by a resident of the other Contracting State;e) the term international traffic means any transport by a ship or aircraft operatedby an enterprise that has its place of effective management in a Contracting State,except when the ship or aircraft is op
13、erated solely between places in the otherContracting State;f) the term petent authority means:(i) (in State A): .(ii) (in State B): .g) the term national, in relation to a Contracting State, means:(i) any individual possessing the nationality or citizenship of that ContractingState; and(ii) any lega
14、l person, partnership or association deriving its status as such fromthe laws in force in that Contracting State;h) the term business includes the performance of professional services and of otheractivities of an independent character.2. As regards the application of the Convention at any time by a
15、Contracting State, anyterm not defined therein shall, unless the context otherwise requires, have the meaning thatit has at that time under the law of that State for the purposes of the taxes to which theConvention applies, any meaning under the applicable tax laws of that State prevailing overa meaning given to the term under other laws of that State.Article 4RESIDENT1. For the purposes of this Conventi
