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–Request:
Please compare the Double Tax Treaty (DTT) you have been provided with the OECD Model
Convention.
The articles covered are as follows:
Article 4-Residency
Article 5-Permanent establishment
Article 7-Business profits
Article 10-Dividends
Article 12-Royalty
Article 13-Capital Gains
Article 23-Elimination of Double Taxation
Article 25-Mutual Agreement Procedure
–What is expected from you:
your DTT to analyze is turkey-Norway DTT
Select 5 articles from the above
Please find the differences between the turkey -Norway DTT and OECD Model Convention. You will compare
the DTT and OECD Model Convention limited with the 5 articles selected from above
You will only elaborate on the differences and provide your thoughts and comments
concerning the reasons of the differences
You do not need to directly copy/paste the articles to your essay, but it is expected your
thoughts/views on the differences. Therefore, please focus on the differences.
the essay shouldn’t be less than 1100 words
The DTTs, OECD Model Convention and Commentary has been in uploaded files

international taxation
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