GTTC Model Articles and Issues - Chapters

General Introduction – Global Tax Treaty Commentaries https://doi.org/10.59403/1w3nqr1
Article 1: Persons Covered – Global Tax Treaty Commentaries https://doi.org/10.59403/32ycsyd
Article 2: Taxes Covered – Global Tax Treaty Commentaries https://doi.org/10.59403/2jgaake
Articles 3, 30, 31 and 32: General Definitions and Scope in Place and Time – Global Tax Treaty Commentaries https://doi.org/10.59403/30yx7ss
Article 4: Resident - Global Tax Treaty Commentaries https://doi.org/10.59403/3w83fv4
Article 5: Permanent Establishment - Global Tax Treaty Commentaries https://doi.org/10.59403/3z734hj
Article 6: Income from Immovable Property – Global Tax Treaty Commentaries https://doi.org/10.59403/30hrft
Article 7: Business Profits - Global Tax Treaty Commentaries https://doi.org/10.59403/3e4qh0d
Article 8: International Shipping and Air Transport (and Related Operations) - Global Tax Treaty Commentaries https://doi.org/10.59403/3asx9s2
Article 9: Associated Enterprises - Global Tax Treaty Commentaries https://doi.org/10.59403/z4r6vg
Article 10: Dividends - Global Tax Treaty Commentaries https://doi.org/10.59403/208fzvq
Article 11: Interest – Global Tax Treaty Commentaries https://doi.org/10.59403/wqvrzp
Article 12: Royalties - Global Tax Treaty Commentaries https://doi.org/10.59403/2c5v9r5
Article 12A UN Model (2017-2021) on Fees for Technical Services https://doi.org/10.59403/15r4rta
Article 12AA UN Model (2025): Fees for Services https://doi.org/10.59403/3pemp13
Article 12B (UN Model): Income from Automated Digital Services https://doi.org/10.59403/yewfnd
Article 13: Capital Gains - Global Tax Treaty Commentaries https://doi.org/10.59403/1eh49fp
Article 14 UN Model (1980-2021): Independent Personal Services - Global Tax Treaty Commentaries https://doi.org/10.59403/26dgy8n
Article 15: Income from Employment/Dependent Personal Services - Global Tax Treaty Commentaries https://doi.org/10.59403/3y3b40w
Article 16: Directors’ Fees/Directors’ Fees and Remuneration of Top-Level Management Officials - Global Tax Treaty Commentaries https://doi.org/10.59403/1y9znb2
Article 17: Entertainers and Sportspersons/Artistes and Sportspersons - Global Tax Treaty Commentaries https://doi.org/10.59403/3099m4z
Articles 18 and 19(2): Pensions/Pensions and Social Security Payments – Global Tax Treaty Commentaries https://doi.org/10.59403/qg92pt
Articles 19(1), 19(3) and 28: Government Service and Members of Diplomatic Missions and Consular Posts - Global Tax Treaty Commentaries https://doi.org/10.59403/1dyy02q
Article 20 – Students, Teachers and Professors - Global Tax Treaty Commentaries https://doi.org/10.59403/30rdwrw
Article 21 - Other Income – Global Tax Treaty Commentaries https://doi.org/10.59403/1dv0m29
Article 22: Capital – Global Tax Treaty Commentaries https://doi.org/10.59403/2g18eeq
Article 23: Methods for Elimination of Double Taxation https://doi.org/10.59403/1w75rzq
Article 24: Non-Discrimination - Global Tax Treaty Commentaries https://doi.org/10.59403/y5zc1t
Article 25: Mutual Agreement Procedure - Global Tax Treaty Commentaries https://doi.org/10.59403/30r20g5
Article 26: Exchange of Information - Global Tax Treaty Commentaries https://doi.org/10.59403/3sc8t98
Article 27: Assistance in the Collection of Taxes – Global Tax Treaty Commentaries https://doi.org/10.59403/333b9h4
Article 29: Entitlement to Benefits (EU perspective) – Global Tax Treaty Commentaries https://doi.org/10.59403/223czwx
Article 29: Entitlement to Benefits (Global Perspective) – Global Tax Treaty Commentaries https://doi.org/10.59403/298vkdh
Treaty Interpretation - Global Tax Treaty Commentaries https://doi.org/10.59403/28gvnh
Application of Tax Treaties to Fiscally Transparent Entities – Global Tax Treaty Commentaries https://doi.org/10.59403/w9461r
Qualification Conflicts - Global Tax Treaty Commentaries https://doi.org/10.59403/qy75t5
Triangular Cases – Global Tax Treaty Commentaries https://doi.org/10.59403/tvntdm
Time in Tax Treaties - Global Tax Treaty Commentaries https://doi.org/10.59403/387kqgb
Beneficial Ownership – Global Tax Treaty Commentaries https://doi.org/10.59403/1vxbn2t
Global Minimum Taxation and Tax Treaties – Global Tax Treaty Commentaries https://doi.org/10.59403/1863tec