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)