—Request:
Please compare the Double Tax Treaty (“DTT”) you have been provided with the OECD Model
Convention.
The articles covered are as follows:
Article 4-Residency
Article 5-Permanent establishment
Article 7-Business profits
Article 10-Dividends
Article 12-Royalty
Article 13-Capital Gains
Article 23-Elimination of Double Taxation
Article 25-Mutual Agreement Procedure
–What is expected from you:
·your DTT to analyze is turkey-Norway DTT
· Select 5 articles from the above
· Please find the differences between the DTT and OECD Model Convention. You will compare
the DTT and OECD Model Convention limited with the 5 articles selected from above
· You will only elaborate on the differences and provide your thoughts and comments
concerning the reasons of the differences
· While making your study on the differences if you need (therefore it is optional),
o You can look into the OECD Model Commentary to understand the differences
amongst the countries/treaties.
o You can visit https://gib.gov.tr/en
· You do not need to directly copy/paste the articles to your essay, but it is expected your
thoughts/views on the differences. Therefore, please focus on the differences.
the essay shouldn’t be less than 1100 words
The DTTs, OECD Model Convention and Commentary has been in uploaded files
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