Examples of using Model convention in English and their translations into Spanish
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Official
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Colloquial
23 B of the Model Convention and conflicts of qualification
This paragraph, which reproduces Article 8, paragraph 1, of the OECD Model Convention, has the objective of ensuring that profits from the operation of ships
which reproduce Article 8, paragraph 3, of the OECD Model Convention, refers to the case in which the place of effective management of the enterprise concerned is aboard a ship
It was also explicitly contrary to paragraph 3 of the article of the United Nations Model Convention, which did not allow deductions for such notional payments although banks were treated as a special case in the case of notional interest.
The OECD Model Convention, as amended in 2005, includes a provision that would allow the sharing of information obtained under article 26 with persons charged with the oversight of the persons allowed to obtain such information.
Option I: To include an arbitration provision in article 25 of the United Nations Model Convention, together with a footnote indicating that the contracting States,
According to the commentary to the OECD Model Convention, the article does not apply to payments for new information obtained as a result of performing services at the request of the payer since it is intended to be limited.
of the OECD commentary, without adopting parts of it that were not agreed as relevant to article 7 of the United Nations Model Convention.
inserted immediately after quotation of paragraph 44 of the OECD Model Convention, would read.
the commentary on article 9 of the United Nations Model Convention was considered,
A note(E/C.18/2011/CRP.2/Add.3) had been prepared by Claudine Devillet on the possible inclusion of article 23 A of the OECD Model Convention, in particular paragraph 4,
The BEPS project will lead to changes in the OECD Model Convention and the Transfer Pricing Guidelines,
The central question raised was whether a provision similar to article 27 of the OECD Model Convention, dealing with assistance in collection, should be included in
A member of the subcommittee also suggested that the exchange of information not be extended in the model convention to all taxes, including subnational taxes,
which places less emphasis than the OECD Model Convention on a more substantial presence as an indicia of economic engagement in a country,
divergences between the United Nations Model Convention and the OECD Model Convention were discussed, with a view
the United Nations Model Convention takes on board some of the updated OECD Model Convention commentaries where they are seen as relevant to interpreting
The OECD Model Convention commentary on article 18 also recognizes that social security payments may be regarded by some States as being similar to Government pensions,
The wording of paragraph 6 of the OECD Model Convention commentary was changed in 2005 from that quoted in the 2001 United Nations Model. .
The United Nations Model Convention commentary, in contrast, merely provides as
