Treaties & certainty / Advanced
UN Model Double Taxation Convention
The 2021 UN model convention and commentary used as a reference in bilateral tax-treaty negotiations.
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The T&M reading note
Why it deserves your time
Supports comparative study of treaty design, especially the allocation of source and residence taxing rights.
A suggested 15-minute first pass
Where to begin
- Read the model article relevant to your topic.
- Read its accompanying commentary.
- Compare with the actual bilateral treaty text.
Read this edition in context
A model convention is a reference text, not a treaty in force between two countries. Selected 2021 edition.
These notes describe the publication; they do not determine the treatment of a particular taxpayer or transaction.
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Official sourcedesapublications.un.org Catalogue review: 2026-10-13