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POSITIONS ON ARTICLE 29

(TERRITORIAL EXTENSION) AND ITS COMMENTARY

1. Indonesia,Malaysia, thePeople’s Republic of China,SingaporeandThailandreserve their position on this Article.(Amended on 15 July 2014 see History)

Title: Redesignated by the report entitled “The 2002 Update to the Model Tax Convention”, adopted by the OECD Council on 28 January 2003. The title, which was included in this section when it was added in 1997, previously read as follows:“POSITIONS ON ARTICLE 28 (TERRITORIAL EXTENSION) AND ITS COMMENTARY”

Paragraph 1Amended on 15 July 2014, by adding Malaysia and Singapore to the list of countries indicating the position, by the Report entitled “The 2014 Update to the Model Tax Convention”, adopted by the Council of the OECD on 15 July 2014. After 22 July 2010 and until 15 July 2014, paragraph 1 read as follows:“1. Indonesia, thePeople’s Republic of ChinaandThailandreserve their position on this Article.”

Paragraph 1 was previously amended on 22 July 2010, by adding Indonesia as a country indicating the position, by the report entitled “The 2010 Update to the Model Tax Convention”, adopted by the OECD Council on 22 July 2010. After 17 July 2008 and until 22 July 2010, paragraph 1 read as follows:“1. ThePeople’s Republic of ChinaandThailandreserve their position on this Article.”

Paragraph 1 was previously amended on 17 July 2008, by replacing “China” with “the People’s Republic of China”, by the report entitled “The 2008 Update to the Model Tax Convention”, adopted by the OECD Council on 17 July 2008. After 28 January 2003 and until 17 July 2008, paragraph 1 read as follows:“1. ChinaandThailandreserve their position on this Article.”

Paragraph 1 as it read after 28 January 2003 corresponded to the position on paragraph 28. Paragraph 1 of the positions on Article 28 was redesignated paragraph 1 of the positions on Article 29 by the report entitled “The 2002 Update to the Model Tax Convention”, adopted by the OECD Council on 28 January 2003.

Paragraph 1 of the positions on Article 28, as it read before 28 January 2003, was included when this section was added in 1997 by the report entitled “The 1997 Update to the Model Tax Convention”, adopted by the OECD Council on 23 October 1997.