The UK does not follow the OECD Model on Income and Capital entirely in specifying the taxes that are within the scope of UK treaties. Typically, para. 1 and 2 of art. 2 of the OECD Model specify the relevant taxes in general terms. A number of treaties, particularly those with Eastern European countries, do, however, adopt the OECD Model in describing the taxes covered in general terms. The Lithuanian Treaty provides an example:
‘–2(1) This Convention shall apply to taxes on income and on capital gains imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
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