2005年OECD税收协定范本(中英对照文本.doc

MODEL CONVENTION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL TITLE AND PREAMBLE CHAPTER I Scope of the Convention Art. 1 Persons Covered Art. 2 Taxes covered CHAPTER II Definitions Art. 3 General definitions Art. 4 Resident Art. 5 Permanent establishment CHAPTER III Taxation of income Art. 6 Income from immovable property Art. 7 Business profits Art. 8 Shipping, inland waterways transport and air transport Art. 9 Associated enterprises Art. 10 Dividends Art. 11 Interest Art. 12 Royalties Art. 13 Capital gains Art. 14 [Deleted] Art. 15 Income from employment Art. 16 Directors’ fees Art. 17 Artistes and sportsmen Art. 18 Pensions Art. 19 Government Service Art. 20 Students Art. 21 Other income CHAPTER IV Taxation of capital Art. 22 Capital CHAPTER V Methods for elimination of double taxation Art. 23 A Exemption method Art. 23 B Credit method CHAPTER VI Special provisions Art. 24 Non-discrimination Art. 25 Mutual agreement procedure Art. 26 Exchange of information Art. 27 Assistance in the collection of taxes Art. 28 Members of diplomatic missions and consular posts Art. 29 Territorial extension CHAPTER VII Final provisions Art. 30 Entry into force Art. 31 Termination TITLE OF THE CONVENTION Convention between (State A) and (State B) with respect to taxes on income and on capital1 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. CHAPTER I SCOPE OF THE CONVENTION Article 1 PERSONS COVERED This Convention shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED 1. This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political subdivis