UNITEDSTATESMODEL.PDFVIP

UNITED STATES MODEL INCOME TAX CONVENTION OF NOVEMBER 15, 2006 CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF ------- FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the United States of America and the Government of -----, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, have agreed as follows: 2006 U.S. Model Income Tax Convention - 2 - Article 1 GENERAL SCOPE 1. This Convention shall apply only to persons who are residents of one or both of the Contracting States, except as otherwise provided in the Convention. 2. This Convention shall not restrict in any manner any benefit now or hereafter accorded: a) by the laws of either Contracting State; or b) by any other agreement to which the Contracting States are parties. 3. a) Notwithstanding the provisions of subparagraph b) of paragraph 2 of this Article: i) for purposes of paragraph 3 of Article XXII (Consultation) of the General Agreement on Trade in Services, the Contracting States agree that any question arising as to the interpretation or application of this Convention and, in particular, whether a taxation measure is within the scope of this Convention, shall be determined exclusively in accordance with the provisions of Article 25 (Mutual Agreement Procedure) o