General Comment
Agreements for the avoidance of double taxation are bilateral
Conventions (herein, sometimes referred to as "treaties")
between sovereign States. The personal scope article of the
Convention usually restricts treaty benefits to persons who are
residents of the Contracting States ("treaty partners").
For example, Article I of the OECD Model Convention
(2017)1:
This Convention shall apply to persons who are residents of one
or both of the Contracting States.
and the United Nations Model Double Taxation Convention between
Developed and Developing Countries (1980) (2017 Update)
("UN Model Convention").
and Article 1 of the United States Model Income Tax
Convention (2016):2
