Interpretation of the Convention Clause Samples

Interpretation of the Convention a) It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD Model Convention on Income and on Capital shall generally be expected to have the same meaning as expressed in the OECD Commentaries thereon as they may be revised from time to time. The understanding in the preceding sentence will not apply with respect to the following: (i) observations to the OECD Commentaries maintained by either Contracting State other than observations made after the signature of this Convention on Commentaries that existed before its signature; (ii) any contrary interpretations in this Protocol; (iii) any contrary interpretation in a published explanation by one of the Contracting States that has been provided to the competent authority of the other Contracting State before the signature of the Convention; (iv) any contrary interpretation agreed by the competent authorities after signature of the Convention. The OECD Commentaries – as they may be revised from time to time – constitute a means of interpretation in the sense of the Vienna Convention of 23 May 1969 on the Law of Treaties. b) Improper use of this Convention

Interpretation of the Convention. It is understood that the OECD and UN Model Commentaries – as they may be revised from time to time – constitute a means of interpretation in the sense of Vienna Convention of 23 May 1969 on the Law of Treaties as far as the provisions of this Convention correspond to those Model Conventions and subject to any contrary interpretations in this Protocol and any contrary interpretation agreed to by the competent authorities after the entry into force of this Convention or any future reservations or observations to the OECD and UN Model or their Commentaries by either Contracting State.

Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD Model Convention on Income and on Capital shall generally be expected to have the same meaning as expressed in the Commentaries thereon.

Interpretation of the Convention. The OECD Commentary - as it may be revised from time to time - constitutes a means of interpretation in the sense of Article 32 of the Vienna Convention of 23 May 1969 on the Law of Treaties.

Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD-Model Convention on Income and on Capital or the United Nations Model Double Taxation Convention between Developed and Developing Countries with respect to Taxes on Income and on Capital shall generally be expected to have the same meaning as expressed in the OECD or UN Commentary thereon. The understanding in the preceding sentence will not apply with respect to any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The Commentaries - as they may be revised from time to time - constitute a means of interpretation in the sense of the Vienna Convention of 23rd May 1969 on the Law of Treaties. In case of any divergence in the interpretation as expressed in the commentaries of the OECD and the UN Model, a common interpretation would have to be sought by mutual agreement according to Article 25, if necessary.

Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD-Model Convention on Income shall generally be expected to have the same meaning as expressed in the OECD Commentary thereon. The understanding in the preceding sentence will not apply with respect to the following: a) any reservations or observations to the OECD Model or its Commentary by either Contracting State; b) any contrary interpretations in this Protocol;

Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD-Model Convention on Income and on Capital or the United Nations Model Double Taxation Convention between developed and developing countries with respect to taxes on income and on capital shall generally be expected to have the same meaning as expressed in the OECD or UN Commentaries thereon. The understanding in the preceding sentence will not apply with respect to the following: a) any reservations or observations to the OECD or UN Model or its Commentaries by either Contracting State; b) any contrary interpretations in this Protocol; c) any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The OECD or UN Commentaries - as they may be revised from time to time - constitute a means of interpretation in the sense of the Vienna Convention of 23 May 1969 on the Law of Treaties. In case of any divergence in the interpretation as expressed in the commentaries of the OECD and UN Model, a common interpretation would have to be sought by mutual agreement according to Article 26 if necessary.

Interpretation of the Convention. It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD-Model Convention on Income and on Capital shall generally be expected to have the same meaning as expressed in the OECD Commentary thereon, as it may be revised from time to time. The understanding in the preceding sentence will not apply with respect to the following: a) any reservations or observations to the OECD Model or its Commentary by either Contracting State; b) any contrary interpretations in this Protocol; c) any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention.

Interpretation of the Convention. In the interpretation and application of the provisions of this Convention regard shall be had to its international character and to the need to promote uniformity.