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DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE CONVENTION BETWEEN THE UNITED STATES OF AMERICA AND THE REPUBLIC OF ESTONIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
GENERAL EFFECTIVE DATE UNDER ARTICLE 28: 1 JANUARY 2000
This is a technical explanation of the Convention between the United States and the Republic of Estonia signed on January 15, 1998 (the ``Convention'').
Negotiations took into account the U.S. Treasury Department's current tax treaty policy and the U.S. Treasury Department's Model Income Tax Convention published on September 20, 1996 (the ``U.S. Model'') between the first and second rounds of negotiations for this Convention, as well as the Model Income Tax Convention On Income and On Capital published by the Organization for Economic Cooperation and Development, as updated in November, 1997 (the ``OECD Model'') and recent tax treaties concluded by both countries.
The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention. References in the Technical Explanation to ``he'' or ``his'' should be read to mean ``he or she'' or ``his or her''.
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