In this booklet a comparative survey is offered offour model income tax conventions: the OECD drafts of 1963 and 1977, the United Nations Model of 1980 and the proposed United States Treasury''s model of 1981. In order to facilitate the compari­ son, the text of the 1977 OECD draft is used as reference. Additions and alternatives in any of the other models to this 1977 OECD text are italicized. Omissions from the 1977 OECD model in the other drafts are indicated either by a blank space (where an entire paragraph has been suppressed) or by brackets [] ( in case of smaller omissions). The Hague, May 1983 Kees van Raad OECD 1963 OECD 1977 OECD DRAFT DOUBLE TAXA­ OECD MODEL DOUBLE TAXA­ TION CONVENTION ON INCOME TION CONVENTION ON INCOME AND CAPITAL AND CAPITAL 1963 1977 TITLE[] TITLE OF THE CONVENTION Convention between (State A) and (State Convention between (State A) and (State B) for the avoidance of double taxation B) for the avoidance of double taxation with respect to taxes on income and on with respect to taxes on income and m capital capital 1 PREAMBLE OF THE CONVENTION CHAPTER I CHAPTER I SCOPE OF THE CONVENTION SCOPE OF THE CONVENTION Article 1 Article 1 PERSONAL SCOPE PERSONAL SCOPE This Convention shall apply to persons This Convention shall apply to persons who are residents of one or both of the who are residents of one or both of the Contracting States. Contracting States.

In this booklet a comparative survey is offered offour model income tax conventions: the OECD drafts of 1963 and 1977, the United Nations Model of 1980 and the proposed United States Treasury''s model of 1981. In order to facilitate the compari­ son, the text of the 1977 OECD draft is used as reference. Additions and alternatives in any of the other models to this 1977 OECD text are italicized. Omissions from the 1977 OECD model in the other drafts are indicated either by a blank space (where an entire paragraph has been suppressed) or by brackets [] ( in case of smaller omissions). The Hague, May 1983 Kees van Raad OECD 1963 OECD 1977 OECD DRAFT DOUBLE TAXA­ OECD MODEL DOUBLE TAXA­ TION CONVENTION ON INCOME TION CONVENTION ON INCOME AND CAPITAL AND CAPITAL 1963 1977 TITLE[] TITLE OF THE CONVENTION Convention between (State A) and (State Convention between (State A) and (State B) for the avoidance of double taxation B) for the avoidance of double taxation with respect to taxes on income and on with respect to taxes on income and m capital capital 1 PREAMBLE OF THE CONVENTION CHAPTER I CHAPTER I SCOPE OF THE CONVENTION SCOPE OF THE CONVENTION Article 1 Article 1 PERSONAL SCOPE PERSONAL SCOPE This Convention shall apply to persons This Convention shall apply to persons who are residents of one or both of the who are residents of one or both of the Contracting States. Contracting States.

In this booklet a comparative survey is offered offour model income tax conventions: the OECD drafts of 1963 and 1977, the United Nations Model of 1980 and the proposed United States Treasury''s model of 1981. In order to facilitate the compari­ son, the text of the 1977 OECD draft is used as reference. Additions and alternatives in any of the other models to this 1977 OECD text are italicized. Omissions from the 1977 OECD model in the other drafts are indicated either by a blank space (where an entire paragraph has been suppressed) or by brackets [] ( in case of smaller omissions). The Hague, May 1983 Kees van Raad OECD 1963 OECD 1977 OECD DRAFT DOUBLE TAXA­ OECD MODEL DOUBLE TAXA­ TION CONVENTION ON INCOME TION CONVENTION ON INCOME AND CAPITAL AND CAPITAL 1963 1977 TITLE[] TITLE OF THE CONVENTION Convention between (State A) and (State Convention between (State A) and (State B) for the avoidance of double taxation B) for the avoidance of double taxation with respect to taxes on income and on with respect to taxes on income and m capital capital 1 PREAMBLE OF THE CONVENTION CHAPTER I CHAPTER I SCOPE OF THE CONVENTION SCOPE OF THE CONVENTION Article 1 Article 1 PERSONAL SCOPE PERSONAL SCOPE This Convention shall apply to persons This Convention shall apply to persons who are residents of one or both of the who are residents of one or both of the Contracting States. Contracting States.