PART A Double Taxation Avoidance Agreements History of Model Convention Important Terms Article 1 Persons Covered Article 2 Taxes Covered Article 3 General Definitions Article 4 Resident Article 5 Permanent Establishment Article 6 Income from Immovable Property Article 7 Business Profits Article 8 Shipping, Inland Waterways Transport and Air Transport Article 9 Associated Enterprises Article 10 Dividends Article 11 Interest Article 12 Royalty Article 13 Capital Gains Article 14 Independent Personal Services Article 15 Dependent Personal Services Article 16 Director’s Fees and Remuneration of Top Level Managerial Officials Article 17 Artistes and Sportspersons Article 18 Pension and Social Security Payments Article 19 Government Service Article 20 Students Article 21 Other Income Article 22 Capital Article 23 Methods for the Elimination of Double Taxation Article 24 Non-Discrimination Article 25 Mutual Agreement Procedure Article 26 Exchange of Information Article 27 Assistance in the Collection of Taxes Article 28 Members of Diplomatic Missions and Consular Posts Article 29 Entry into Force Article 30 Termination PART B Miscellaneous Topics 1. Base Erosion and Profit Sharing (BEPS) 2. Foreign Tax Credit (FTC) 3. Place of Effective Management (POEM) 4. General Anti Avoidance Rules (GAAR) 5. Multi-Lateral Instrument (MLI) |