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States wishing to do so may follow the widespread practice of including
in the title a reference to either the avoidance of double taxation or to
both the avoidance of double taxation and the prevention of fiscal
evasion.
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The Preamble of the Convention shall be drafted in accordance with the
constitutional procedure of both Contracting States.
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In some countries, national law, policy or administrative considerations
may not allow or justify the type of assistance envisaged under this
Article or may require that this type of assistance be restricted, e.g.
to countries that have similar tax systems or tax administrations or as
to the taxes covered. For that reason, the Article should only be
included in the Convention where each State concludes that, based on the
factors described in paragraph 1 of the Commentary on the Article, they
can agree to provide assistance in the collection of taxes levied by the
other State.
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The words between brackets are of relevance when, by special provision, a
part of the territory of a Contracting State is excluded from the
application of the Convention.
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The terminal clause concerning the signing shall be drafted in accordance
with the constitutional procedure of both Contracting States.
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