The Model Convention tries, wherever possible to specify a
single rule for each situation. However on some points it leaves a
certain degree of flexibility, compatible with the efficient
interpretation of the Model. So although all members of the OECD
will adhere in the main to the Model, there is a degree of latitude
allowed with respect to e.g. agreeing reduced rates of withholding
tax, or how double taxation will be relieved. The Model also
mentions alternative or additional provisions for some cases.
Some countries have recorded Observations on various
Articles. These do not express disagreement with the text of the
Model but usefully indicate how that country will apply the
provisions of the Article in question.
Nearly all Member countries have entered a Reservation
against one or other of the provisions. For the UK, these often
reserve the right to negotiate special treatment for off-shore
activities.
