Artikel I

It is understood that provisions of the Convention which are drafted according to the corresponding provisions of the OECD Model Tax Convention on income and on capital or the United Nations Model Double Taxation Convention between Developed and Developing Countries shall generally be expected to have the same meaning as expressed in the OECD or UN Commentaries thereon. The understanding in the preceding sentence will not apply with respect to any contrary interpretation agreed to by the competent authorities after the entry into force of the Convention. The Commentaries – as they may be revised from time to time – constitute a means of interpretation. In case of any divergence in the interpretation as expressed in the commentaries of the OECD and the UN Model, a common interpretation would have to be sought by mutual agreement according to Article 26, if necessary.