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Model Tax Convention on Income and on capital

Model Tax Convention## Title of the Convention

Convention between (State A) and (State B)

with respect to taxes on income and on capitalStates wishing to do so may follow the widespread practice of including in the title a reference to either the avoidance of double taxation or to both the avoidance of double taxation and the prevention of fiscal evasion.

Preamble to the Convention2

  1. States wishing to do so may follow the widespread practice of including in the title a reference to either the avoidance of double taxation or to both the avoidance of double taxation and the prevention of fiscal evasion. ↩

  2. The Preamble of the Convention shall be drafted in accordance with the constitutional procedure of both Contracting States. ↩

  3. In some countries, national law, policy or administrative considerations may not allow or justify the type of assistance envisaged under this Article or may require that this type of assistance be restricted, e.g. to countries that have similar tax systems or tax administrations or as to the taxes covered. For that reason, the Article should only be included in the Convention where each State concludes that, based on the factors described in paragraph 1 of the Commentary on the Article, they can agree to provide assistance in the collection of taxes levied by the other State. ↩