This section of commentary considers how, in general, a number of important concepts are dealt with in double taxation agreements concluded by the UK. As most agreements follow closely the OECD Model Tax Convention, this commentary is based on how those concepts are addressed in that Model. However, in dealing with a specific case it is essential to refer to the actual agreement with the country concerned. It may be based upon an earlier version of the Model or the parties may have agreed to depart from the Model wording.

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