GTTC Model Articles and Issues - Chapters

General Introduction – Global Tax Treaty Commentaries

Article 1: Persons Covered – Global Tax Treaty Commentaries

Article 2: Taxes Covered – Global Tax Treaty Commentaries

Articles 3, 30, 31 and 32: General Definitions and Scope in Place and Time – Global Tax Treaty Commentaries

Article 5: Permanent Establishment - Global Tax Treaty Commentaries

Article 6: Income from Immovable Property – Global Tax Treaty Commentaries

Article 7: Business Profits - Global Tax Treaty Commentaries

Article 8: International Shipping and Air Transport (and Related Operations) - Global Tax Treaty Commentaries

Article 9: Associated Enterprises - Global Tax Treaty Commentaries

Article 10: Dividends - Global Tax Treaty Commentaries

Article 11: Interest – Global Tax Treaty Commentaries

Article 12: Royalties - Global Tax Treaty Commentaries

Article 12A UN Model (2017-2021) on Fees for Technical Services

Article 12AA UN Model (2025): Fees for Services

Article 12B (UN Model): Income from Automated Digital Services

Article 13: Capital Gains - Global Tax Treaty Commentaries

Article 14 UN Model (1980-2021): Independent Personal Services - Global Tax Treaty Commentaries

Article 15: Income from Employment/Dependent Personal Services - Global Tax Treaty Commentaries

Article 16: Directors’ Fees/Directors’ Fees and Remuneration of Top-Level Management Officials - Global Tax Treaty Commentaries

Article 17: Entertainers and Sportspersons/Artistes and Sportspersons - Global Tax Treaty Commentaries

Articles 18 and 19(2): Pensions/Pensions and Social Security Payments – Global Tax Treaty Commentaries

Articles 19(1), 19(3) and 28: Government Service and Members of Diplomatic Missions and Consular Posts - Global Tax Treaty Commentaries

Article 20 – Students, Teachers and Professors - Global Tax Treaty Commentaries

Article 21 - Other Income – Global Tax Treaty Commentaries

Article 22: Capital – Global Tax Treaty Commentaries

Article 23: Methods for Elimination of Double Taxation

Article 24: Non-Discrimination - Global Tax Treaty Commentaries

Article 25: Mutual Agreement Procedure - Global Tax Treaty Commentaries

Article 26: Exchange of Information - Global Tax Treaty Commentaries

Article 27: Assistance in the Collection of Taxes – Global Tax Treaty Commentaries

Article 29: Entitlement to Benefits (EU perspective) – Global Tax Treaty Commentaries

Article 29: Entitlement to Benefits (Global Perspective) – Global Tax Treaty Commentaries

Treaty Interpretation - Global Tax Treaty Commentaries

Application of Tax Treaties to Fiscally Transparent Entities – Global Tax Treaty Commentaries

Qualification Conflicts - Global Tax Treaty Commentaries

Triangular Cases – Global Tax Treaty Commentaries

Time in Tax Treaties - Global Tax Treaty Commentaries

Article 4: Resident - Global Tax Treaty Commentaries

Beneficial Ownership – Global Tax Treaty Commentaries

Global Minimum Taxation and Tax Treaties – Global Tax Treaty Commentaries