Your government has embarked on developing a double taxation model and has contracted you to provide advice in drafting the tax treaty template which will act as a basis for negotiating tax treaties with other states. As part of your terms of reference, you are required to provide advice in the following areas:
The models available to use as a basis for a double tax treaty.
The matters that need to be included in the scope and definition sections of a treaty.
The options available for preventing the granting of treaty benefits in inappropriate circumstances.
The methods available to eliminate double taxation.