https://www.oecd.org/en/publications/the-2025-update-to-the-oecd-model-tax-convention_5798080f-en.html
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Title page 1
Contents 4
Executive summary 6
Changes to be included in the 2025 Update to the Model Tax Convention 7
A. Changes to the Introduction 8
B. Changes to the Articles 9
Article 25 9
C. Changes to the Commentaries 10
Commentary on Article 1 10
Commentary on Article 2 11
Commentary on Article 3 12
Commentary on Article 4 13
Commentary on Article 5 14
Commentary on Article 6 35
Commentary on Article 7 36
Commentary on Article 8 39
Commentary on Article 9 39
Commentary on Article 10 43
Commentary on Article 11 44
Commentary on Article 12 45
Commentary on Article 13 46
Commentary on Article 15 47
Commentary on Article 16 48
Commentary on Article 17 48
Commentary on Article 18 49
Commentary on Article 19 49
Commentary on Article 20 50
Commentary on Article 21 50
Commentary on Article 22 51
Commentary on Articles 23 A and 23 B 51
Commentary on Article 24 51
Commentary on Article 25 52
Commentary on Article 26 59
Commentary on Article 29 60
D. Changes to the Positions of Non-Member Economies 62
Introduction 62
Positions on Article 1 and its Commentary 62
Positions on Article 2 and its Commentary 63
Positions on Article 3 and its Commentary 63
Positions on Article 4 and its Commentary 64
Positions on Article 5 and its Commentary 65
Positions on Article 6 and its Commentary 69
Positions on Article 7 and its Commentary 70
Positions on Article 8 and its Commentary 72
Positions on Article 9 and its Commentary 73
Positions on Article 10 and its Commentary 74
Positions on Article 11 and its Commentary 76
Positions on Article 12 and its Commentary 77
Positions on Article 13 and its Commentary 79
Positions on Article 15 and its Commentary 80
Positions on Article 16 and its Commentary 81
Positions on Article 17 and its Commentary 81
Positions on Article 18 and its Commentary 82
Positions on Article 19 and its Commentary 83
Positions on Article 20 and its Commentary 83
Positions on Article 21 and its Commentary 83
Positions on Article 22 and its Commentary 84
Positions on Articles 23A and 23B and its Commentary 84
Positions on Article 24 and its Commentary 84
Positions on Article 25 and its Commentary 86
Positions on Article 26 and its Commentary 87
Positions on Article 29 and its Commentary 87
Positions on Article 30 and its Commentary 87
Positions on Article 32 and its Commentary 88
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