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D MC. Therefore, in order suit their requirements they usually add or delete and even modify articles present in model tax treaties. However, they basically follow these two model conventions. The United Nations Model Convention was most recently revised in 2011 and the OECD Model Convention in 2014.

1.6 THE DUAL NATURE OF TAX TREATIES
Tax treaties have a dual nature as they are International binding agreements between sovereign states and at the same time part of domestic tax law of their respective states. A tax does not describe a tax system. However, it describes the ultimate limits to which that system may extend. For example: maximum withholding tax rate does not necessarily mean imposition of actual withholding tax. As a general rule a tax treaty does not substantiate any tax liability (or increase any taxes over national tax laws). A tax treaty involves a negotiated sharing of tax revenue by two states and is a connectionbetween two tax systems.

1.7 THE CONTENTS OF TAX TREATIES
Internationally accepted models contain 30 (or 29) standard articles which may be grouped as follows:

Personal Scope: Taxpayers Covered
Material Scope: Scope of Taxes
Territorial Scope: Area Covered
Temporal Scope: Period Covered
Distributive Scope: Tax Sharing
Method of Relief: Exemption or Credit
Commentary to Aid Interpretation
Observations and Reservations
The model treaty comprises of standard clauses, commonly known as articles, which may be amended in negotiations by contracting states. It is governed by the Source Rules, the Assignment Rules and the Relief Rules and has got its specific structure which can be summarized as follows:

Personal and Material Scope
Specifies to whom the convention applies and which taxes are covered– Article 1 & 2.

The Territorial Scope - Specifies the geographical area and the tax jurisdiction covered and the General Definitions
The various terms commonly used in the various articles are defined Article 3, 4& 5

The Assignment rights to the different classes of income – article 6 to 22
Method of Relief
Specifies the methods for relief in cases of double taxation between two tax jurisdictions – article 23A & 23B

Distributive Rules and Special Provisions
Provides the rules for the avoidance of double taxation on income or capital; exchange of information; assistance in collection of taxes – article 24 to 29

The Temporal Scope
Specifies the entry into force and the duration of the treaty – Article 30 & 31

The key concept covered in this chapter were:

International Tax treaties
The role of Vienna Convention on the Law of Treaties
Model Tax Treaty or Double Taxation Avoidance Agreement
The history of DTAs and why they are necessary?
Look at the dual nature of tax treaties; and
The contents of a tax treaty.
Learners will be expected to have gained a detailed knowledge of the topics and be able to apply this knowledge showing an understanding of the issues involved.

1.8 QUESTIONS
What is a tax treaty? How does it differ from other international treaties? What are the different types of tax treaties? What is a Model tax treaty?
Explain the main functions of or reasons for a bilateral t