Common use of Interpretation of the Convention Clause in Contracts

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. 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 in a published explanation by one of the Contracting States that has been provided to the competent authority of the other Contracting State prior to the entry into force of the Convention; d) any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The OECD Commentary - as it may be revised from time to time - constitutes a means of interpretation in the sense 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 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; c) 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 prior to the entry into force of the Convention; d) any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The OECD Commentary - – as it may be revised from time to time - – constitutes a means of interpretation in the sense 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 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; c) 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 prior to the entry into force of the Convention; d) any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The OECD Commentary - as it may be revised from time to time - constitutes a means of interpretation in the sense 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-OECD Model Convention on Income income and on Capital capital 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; c) 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 prior to the entry into force of the Convention;; and dc) any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The OECD Commentary - as it may be revised from time to time - constitutes a means of interpretation in the sense 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 Tax Convention on Income and on Capital 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 as well as any positions on the OECD Model or its Commentary by either Contracting State; b) any contrary interpretations in this Protocol; c) 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 prior to the entry into force of the Convention; d) any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The OECD Commentary - as it may be revised from time to time - constitutes a means of interpretation in the sense of the Vienna Convention of 23 May 1969 on the Law of Treaties.