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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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