- 1
- It is understood that the OECD Commentary as it may be revised from time to time may be an important source of interpretation of the provisions of the Convention which are drafted according to the corresponding provisions of the OECD Model Convention on Income and on Capital.
- 2
- Where entities are considered to be transparent by one of the Contracting States and are considered to be non-transparent by the other Contracting State, and this leads to double taxation or taxation not in accordance with the provisions of this Convention, the competent authorities of the Contracting States shall find solutions pursuant to Article 24 in order to avoid double taxation or taxation not in accordance with the Convention and, at the same time, to prevent that, merely as a result of the application of the Convention, income is (partly) not subject to tax.
