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According to the provisions of the UN Model Agreement, if a taxpayer is under the…
The UN Model does not present an unlimited possibility regarding violations of the…
Similar to the OECD 2014 Model, the UN Model offers two options regarding which competent…
The second option, based on discrimination, derives from paragraph 1 of Article 24…
Providing an example can clarify this issue further. For instance, let’s assume that…
The term “competent authority” is defined in double taxation prevention agreements…
In the commentary of the UN Model, the option to apply to the state of residence…
States are obligated to make efforts to resolve the applications they receive. As…
The UN Model, similar to the OECD Model, provides a mechanism that enables states…
