Abstract

The article presents and discusses in detail the changes that were introduced to art. 5 of OECD Model Tax Convention from 2017. These changes were discussed in regard to practical examples included in the Commentary to the Model Tax Convention. Moreover, the article touches upon a problem of a possibility to apply changes introduced to the Commentary to the Model Tax Convention from 2017, while interpreting agreements on avoiding double taxation (especially art. 5 of these agreements) included before ­adopting the Convention from 2017.