data/processed/reports/cr-2012-306.json

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  "title": "Mongolia: Technical Assistance Report—Safeguarding Domestic Revenue—A Mongolian DTA Model",
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    "series": [
      "IMF Staff Country Reports"
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    "series_volume_no": "Country Report No.  2012/306",
    "doi": [],
    "isbn": [],
    "subjects": [
      "Personal income",
      "Double taxation",
      "Withholding tax",
      "Subnational tax",
      "Corporate income tax",
      "National accounts",
      "Taxes"
    ],
    "topics": [
      "Real sector|National accounts|Income|Personal income ",
      " Real sector|National accounts|Income ",
      " Real sector|National accounts ",
      " Real sector ",
      " Fiscal policy and management|Taxes|International tax issues|Double taxation ",
      " Fiscal policy and management|Taxes|International tax issues ",
      " Fiscal policy and management|Taxes ",
      " Fiscal policy and management ",
      " Fiscal policy and management|Taxes|Income and capital gains taxes|Capital income tax|Withholding tax ",
      " Fiscal policy and management|Taxes|Income and capital gains taxes|Capital income tax ",
      " Fiscal policy and management|Taxes|Income and capital gains taxes ",
      " Fiscal policy and management|Taxes ",
      " Fiscal policy and management ",
      " Fiscal policy and management|Taxes|Subnational tax ",
      " Fiscal policy and management|Taxes ",
      " Fiscal policy and management ",
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      " Real sector ",
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      "text": "For instance, in some cases the Mongolian withholding tax on dividends, interest, royalty, service fees, or lease payments is limited or even prohibited.",
      "verbatim": "For instance, in some cases the Mongolian withholding tax on dividends, interest, royalty, service fees, or lease payments is limited or even prohibited.",
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      "text": "However, in a few years this might change as the exploration of minerals takes off and Mongolia will set up Sovereign Wealth Funds (SFW) using the resources to create sustainable wealth for its citizens.",
      "verbatim": "However, in a few years this might change as the exploration of minerals takes off and Mongolia will set up Sovereign Wealth Funds (SFW) using the resources to create sustainable wealth for its citizens.",
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      "text": "However, terminating DTAs effectively by 1 January of the next calendar year requires a notice through diplomatic channels at the latest on 30 June in the year before.",
      "verbatim": "However, terminating DTAs effectively by 1 January of the next calendar year requires a notice through diplomatic channels at the latest on 30 June in the year before.",
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      "text": "The authorities requested an assessment of their DTA network, identify its weaknesses, and make suggestions for improving their DTAs in future.",
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      "text": "The current Mongolian DTA network, however, is prone to international tax planning as some DTAs contain favorable provisions allowing residents of other countries to substantially reduce source taxation in Mongolia.",
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      "text": "In the current situation, only a few DTAs can be considered potentially harmful as they insufficiently protect the Mongolian tax base.",
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      "text": "Most DTAs—although slightly out of line with the proposed Mongolian DTA Model (see chapter III)—do not require immediate attention.",
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      "text": "Negotiating or renegotiating DTAs does not only require the development of an international tax treaty policy (i.e.",
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      "text": "however, have a slightly different wording, which suggests that these DTAs are extended for periods of 5 years and can only be terminated after such period elapses.",
      "verbatim": "however, have a slightly different wording, which suggests that these DTAs are extended for periods of 5 years and can only be terminated after such period elapses.",
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      "text": "In addition, the CIT contains a provision that allows the tax authorities to challenge transactions between related parties—including headquarter and permanent establishment—and correct (increase or reduce) taxable profit.",
      "verbatim": "In addition, the CIT contains a provision that allows the tax authorities to challenge transactions between related parties—including headquarter and permanent establishment—and correct (increase or reduce) taxable profit.",
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      "text": "In this chapter, an overview is provided of the most critical provisions in those tax treaties currently in force, an analysis is made of their strengths and weaknesses, and suggestions are given to improve them.",
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      "text": "Although all DTAs include a transfer pricing provision allowing Mongolia to challenge profit realization on transactions between associated persons, a number of DTAs do not contain an obligation to apply a corresponding adjustment.",
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      "text": "Mongolia, however, cannot tax this constructor based on the CIT (requires 6 months construction activities).",
      "verbatim": "Mongolia, however, cannot tax this constructor based on the CIT (requires 6 months construction activities).",
      "topic": "Geerten M.M. Michielse June 2012",
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      "text": "permanent establishment) as is allowed under its DTAs and can effectively tax non-resident companies and entrepreneurs according to the rules laid down in the CIT and PIT.",
      "verbatim": "permanent establishment) as is allowed under its DTAs and can effectively tax non-resident companies and entrepreneurs according to the rules laid down in the CIT and PIT.",
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          "quote": "permanent establishment) as is allowed under its DTAs and can effectively tax non-resident companies and entrepreneurs according to the rules laid down in the CIT and PIT.",
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      "text": "If the service provider does not maintain a permanent establishment in Mongolia, but performs a service in Mongolia, payments are subject to a 20 per cent withholding tax.",
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      "text": "In DTAs that do not contain a “service-pe”, the domestic rule cannot be applied unless a regular pe can be construed.",
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      "text": "In some DTAs Mongolia has safeguarded its right to levy a limited tax (whether by withholding or not) on ―technical fees‖.",
      "verbatim": "In some DTAs Mongolia has safeguarded its right to levy a limited tax (whether by withholding or not) on ―technical fees‖.",
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      "text": "Establishing domestic legislation to tax those payments is an effective anti-abuse measure.",
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      "text": "The DTA with the United Arab Emirates does not allow the source state to levy a withholding tax.",
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      "text": "Also the DTA with the United Arab Emirates is in this respect of concern, as the UAE does not levy income taxes (except for oil and gas production).",
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    },
    {
      "text": "However, the capital gain is only taxed if more than 50 per cent of the value of the shares is attributable to such an exploration license, a mining license, and/or other depreciable assets used in mining activities in Mongolia, and if at least 10 per cent of the shares is sold.",
      "verbatim": "However, the capital gain is only taxed if more than 50 per cent of the value of the shares is attributable to such an exploration license, a mining license, and/or other depreciable assets used in mining activities in Mongolia, and if at least 10 per cent of the shares is sold.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-1a031e34667d251e",
          "page": 15,
          "quote": "However, the capital gain is only taxed if more than 50 per cent of the value of the shares is attributable to such an exploration license, a mining license, and/or other depreciable assets used in mining activities in Mongolia, and if at least 10 per cent of the shares is sold.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0024"
    },
    {
      "text": "The withholding tax cannot be levied if the definition of “royalty” does not cover the use or right to use industrial, commercial, or scientific equipment (i.e.",
      "verbatim": "The withholding tax cannot be levied if the definition of “royalty” does not cover the use or right to use industrial, commercial, or scientific equipment (i.e.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-46faa551d12ca018",
          "page": 15,
          "quote": "The withholding tax cannot be levied if the definition of “royalty” does not cover the use or right to use industrial, commercial, or scientific equipment (i.e.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0025"
    },
    {
      "text": "An indirect sale through the sale of shares in the company owning such licenses is the only method available to investors to transfer the ownership, as the mining law does not allow a direct sale of such licenses.",
      "verbatim": "An indirect sale through the sale of shares in the company owning such licenses is the only method available to investors to transfer the ownership, as the mining law does not allow a direct sale of such licenses.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-8dfdf159643f504a",
          "page": 16,
          "quote": "An indirect sale through the sale of shares in the company owning such licenses is the only method available to investors to transfer the ownership, as the mining law does not allow a direct sale of such licenses.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0026"
    },
    {
      "text": "If DTAs do not include a special rule for the indirect sale of immovable property through a sale of shares, Mongolia will not be able to execute its domestic taxing right.",
      "verbatim": "If DTAs do not include a special rule for the indirect sale of immovable property through a sale of shares, Mongolia will not be able to execute its domestic taxing right.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-9f6a5c9e6928ec94",
          "page": 16,
          "quote": "If DTAs do not include a special rule for the indirect sale of immovable property through a sale of shares, Mongolia will not be able to execute its domestic taxing right.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0027"
    },
    {
      "text": "Mongolia is only able to safeguard its taxing rights on an indirect sale of exploration and mining licenses in a limited number of DTAs.",
      "verbatim": "Mongolia is only able to safeguard its taxing rights on an indirect sale of exploration and mining licenses in a limited number of DTAs.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-5f56753960018994",
          "page": 16,
          "quote": "Mongolia is only able to safeguard its taxing rights on an indirect sale of exploration and mining licenses in a limited number of DTAs.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0028"
    },
    {
      "text": "The capital gain on the sale of property used in international traffic is taxable in the country where the company has its place of effective management.",
      "verbatim": "The capital gain on the sale of property used in international traffic is taxable in the country where the company has its place of effective management.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-727a7d444f20262f",
          "page": 16,
          "quote": "The capital gain on the sale of property used in international traffic is taxable in the country where the company has its place of effective management.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0029"
    },
    {
      "text": "In all DTAs providing limited taxing rights for payment of dividends, interest, and royalties, the limited rights are conditional upon the recipient being the ―beneficial owner‖ of these payments.",
      "verbatim": "In all DTAs providing limited taxing rights for payment of dividends, interest, and royalties, the limited rights are conditional upon the recipient being the ―beneficial owner‖ of these payments.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-139675ac6f9b2208",
          "page": 20,
          "quote": "In all DTAs providing limited taxing rights for payment of dividends, interest, and royalties, the limited rights are conditional upon the recipient being the ―beneficial owner‖ of these payments.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0030"
    },
    {
      "text": "Mongolia does not have provisions in its domestic tax legislation dealing with international tax planning other than the possibility to modify income on transactions between associated persons.",
      "verbatim": "Mongolia does not have provisions in its domestic tax legislation dealing with international tax planning other than the possibility to modify income on transactions between associated persons.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-66492c8528ab0bcd",
          "page": 20,
          "quote": "Mongolia does not have provisions in its domestic tax legislation dealing with international tax planning other than the possibility to modify income on transactions between associated persons.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0031"
    },
    {
      "text": "Mongolia has not developed an interpretation of this concept, which makes the limitation in the DTAs ineffective.",
      "verbatim": "Mongolia has not developed an interpretation of this concept, which makes the limitation in the DTAs ineffective.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-135e723c436a84b9",
          "page": 20,
          "quote": "Mongolia has not developed an interpretation of this concept, which makes the limitation in the DTAs ineffective.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0032"
    },
    {
      "text": "A simplified version may, however, serve the purpose for Mongolia.",
      "verbatim": "A simplified version may, however, serve the purpose for Mongolia.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-c9ac9709f2b3776a",
          "page": 21,
          "quote": "A simplified version may, however, serve the purpose for Mongolia.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0033"
    },
    {
      "text": "Currently Mongolian DTAs contain no effective protection against treaty shopping, except through the (non-developed) concept of ―beneficial ownership‖.",
      "verbatim": "Currently Mongolian DTAs contain no effective protection against treaty shopping, except through the (non-developed) concept of ―beneficial ownership‖.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-944dd6f41d55d061",
          "page": 21,
          "quote": "Currently Mongolian DTAs contain no effective protection against treaty shopping, except through the (non-developed) concept of ―beneficial ownership‖.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0034"
    },
    {
      "text": "In the DTAs with India, Italy, and Kazakhstan this exemption is limited to 5 years.",
      "verbatim": "In the DTAs with India, Italy, and Kazakhstan this exemption is limited to 5 years.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-2f04f10b1992420d",
          "page": 21,
          "quote": "In the DTAs with India, Italy, and Kazakhstan this exemption is limited to 5 years.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0035"
    },
    {
      "text": "Most DTAs set that limited period at 2 years.",
      "verbatim": "Most DTAs set that limited period at 2 years.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-299470c963ea62e7",
          "page": 22,
          "quote": "Most DTAs set that limited period at 2 years.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0036"
    },
    {
      "text": "Payments which a professor or teacher, who is a resident of a Contracting State and who is present in the other Contracting State for the purpose of teaching or scientific research for a limited period in a university, college or other establishment for teaching or scientific research in that other State, receives for such teaching or research are taxable only in the state of residence.",
      "verbatim": "Payments which a professor or teacher, who is a resident of a Contracting State and who is present in the other Contracting State for the purpose of teaching or scientific research for a limited period in a university, college or other establishment for teaching or scientific research in that other State, receives for such teaching or research are taxable only in the state of residence.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-88dffc4e3ed98ee4",
          "page": 22,
          "quote": "Payments which a professor or teacher, who is a resident of a Contracting State and who is present in the other Contracting State for the purpose of teaching or scientific research for a limited period in a university, college or other establishment for teaching or scientific research in that other State, receives for such teaching or research are taxable only in the state of residence.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0037"
    },
    {
      "text": "The DTAs with China, Kazakhstan, PR of Korea, Luxemburg, and Russia have the limited period set at 3 years, whereas the DTA with Hungary does not contain any time limit.",
      "verbatim": "The DTAs with China, Kazakhstan, PR of Korea, Luxemburg, and Russia have the limited period set at 3 years, whereas the DTA with Hungary does not contain any time limit.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-cede6874513b6748",
          "page": 22,
          "quote": "The DTAs with China, Kazakhstan, PR of Korea, Luxemburg, and Russia have the limited period set at 3 years, whereas the DTA with Hungary does not contain any time limit.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0038"
    },
    {
      "text": "A Contracting State can refuse a request for assistance: (a) if the applicant State has not pursued all means available in its own territory; and/or (b) if and insofar as it considers the tax claim to be contrary to the provisions of the DTA or of any other agreement to which both of the States are parties.",
      "verbatim": "A Contracting State can refuse a request for assistance: (a) if the applicant State has not pursued all means available in its own territory; and/or (b) if and insofar as it considers the tax claim to be contrary to the provisions of the DTA or of any other agreement to which both of the States are parties.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-04ceb6d551a26dc0",
          "page": 23,
          "quote": "A Contracting State can refuse a request for assistance: (a) if the applicant State has not pursued all means available in its own territory; and/or (b) if and insofar as it considers the tax claim to be contrary to the provisions of the DTA or of any other agreement to which both of the States are parties.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0039"
    },
    {
      "text": "The procedures, however, are unclear and the reference to the competent authorities to develop such procedures is not contained in the DTAs.",
      "verbatim": "The procedures, however, are unclear and the reference to the competent authorities to develop such procedures is not contained in the DTAs.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-32f08ef8f2066274",
          "page": 24,
          "quote": "The procedures, however, are unclear and the reference to the competent authorities to develop such procedures is not contained in the DTAs.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0040"
    },
    {
      "text": "This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.",
      "verbatim": "This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-0437e0cbf2221af2",
          "page": 26,
          "quote": "This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State or capital situated therein.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0041"
    },
    {
      "text": "(a) he is deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he is deemed to be a resident only of the State with which his personal and economic relations are closer (center of vital interests); (b) if the State in which he has his center of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he is deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he is deemed to be a resident only of the State of which he is a national; (d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States settle the question by mutual agreement.",
      "verbatim": "(a) he is deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he is deemed to be a resident only of the State with which his personal and economic relations are closer (center of vital interests); (b) if the State in which he has his center of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he is deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he is deemed to be a resident only of the State of which he is a national; (d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States settle the question by mutual agreement.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-4463dcc104e85982",
          "page": 27,
          "quote": "(a) he is deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, he is deemed to be a resident only of the State with which his personal and economic relations are closer (center of vital interests); (b) if the State in which he has his center of vital interests cannot be determined, or if he has not a permanent home available to him in either State, he is deemed to be a resident only of the State in which he has an habitual abode; (c) if he has an habitual abode in both States or in neither of them, he is deemed to be a resident only of the State of which he is a national; (d) if he is a national of both States or of neither of them, the competent authorities of the Contracting States settle the question by mutual agreement.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0042"
    },
    {
      "text": "Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it is deemed to be a resident only of the State in which its place of effective management is situated.",
      "verbatim": "Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it is deemed to be a resident only of the State in which its place of effective management is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-72770a4c476a4757",
          "page": 27,
          "quote": "Where by reason of the provisions of paragraph 1 a person other than an individual is a resident of both Contracting States, then it is deemed to be a resident only of the State in which its place of effective management is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0043"
    },
    {
      "text": "However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that",
      "verbatim": "However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-8f119b1a61873144",
          "page": 28,
          "quote": "However, when the activities of such an agent are devoted wholly or almost wholly on behalf of that",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0044"
    },
    {
      "text": "Notwithstanding the preceding provisions of this article, an insurance enterprise of a Contracting State is deemed to have a permanent establishment in the other Contracting State, except in regard to re-insurance, if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies.",
      "verbatim": "Notwithstanding the preceding provisions of this article, an insurance enterprise of a Contracting State is deemed to have a permanent establishment in the other Contracting State, except in regard to re-insurance, if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-965b9aef68d83063",
          "page": 28,
          "quote": "Notwithstanding the preceding provisions of this article, an insurance enterprise of a Contracting State is deemed to have a permanent establishment in the other Contracting State, except in regard to re-insurance, if it collects premiums in the territory of that other State or insures risks situated therein through a person other than an agent of an independent status to whom paragraph 7 applies.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0045"
    },
    {
      "text": "The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), does not of itself constitute either company a permanent establishment of the other.",
      "verbatim": "The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), does not of itself constitute either company a permanent establishment of the other.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-3a1fea75e3d3034a",
          "page": 29,
          "quote": "The fact that a company which is a resident of a Contracting State controls or is controlled by a company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), does not of itself constitute either company a permanent establishment of the other.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0046"
    },
    {
      "text": "However, no such deduction are allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment.",
      "verbatim": "However, no such deduction are allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-3c94c247f9149b68",
          "page": 30,
          "quote": "However, no such deduction are allowed in respect of amounts, if any, paid (otherwise than towards reimbursement of actual expenses) by the permanent establishment to the head office of the enterprise or any of its other offices, by way of royalties, fees or other similar payments in return for the use of patents or other rights, or by way of commission, for specific services performed or for management, or, except in the case of a banking enterprise, by way of interest on moneys lent to the permanent establishment.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0047"
    },
    {
      "text": "In so far as it has been customary in a Contracting State to determine the profit to be attributed to a permanent establishment on the basis of an apportionment of the total profit of the enterprise to its various parts, nothing in paragraph 2 precludes that Contracting State from determining the profit to be taxed by such an apportionment as may be customary; the method of apportionment adopted, however, is such that the result is in accordance with the principles contained in this article.",
      "verbatim": "In so far as it has been customary in a Contracting State to determine the profit to be attributed to a permanent establishment on the basis of an apportionment of the total profit of the enterprise to its various parts, nothing in paragraph 2 precludes that Contracting State from determining the profit to be taxed by such an apportionment as may be customary; the method of apportionment adopted, however, is such that the result is in accordance with the principles contained in this article.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-855a568176b07994",
          "page": 30,
          "quote": "In so far as it has been customary in a Contracting State to determine the profit to be attributed to a permanent establishment on the basis of an apportionment of the total profit of the enterprise to its various parts, nothing in paragraph 2 precludes that Contracting State from determining the profit to be taxed by such an apportionment as may be customary; the method of apportionment adopted, however, is such that the result is in accordance with the principles contained in this article.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0048"
    },
    {
      "text": "If the place of effective management of a shipping enterprise is aboard a ship, then it is deemed to be situated in the Contracting State in which the home harbor of the ship is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident.",
      "verbatim": "If the place of effective management of a shipping enterprise is aboard a ship, then it is deemed to be situated in the Contracting State in which the home harbor of the ship is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-e7d7dd50e3eb37af",
          "page": 31,
          "quote": "If the place of effective management of a shipping enterprise is aboard a ship, then it is deemed to be situated in the Contracting State in which the home harbor of the ship is situated, or, if there is no such home harbor, in the Contracting State of which the operator of the ship is a resident.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0049"
    },
    {
      "text": "Profit from the operation of ships, aircraft, road and railway vehicles in international traffic are taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
      "verbatim": "Profit from the operation of ships, aircraft, road and railway vehicles in international traffic are taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-2db7a00316653e04",
          "page": 31,
          "quote": "Profit from the operation of ships, aircraft, road and railway vehicles in international traffic are taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0050"
    },
    {
      "text": "Where: (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profit which would, but for those conditions, has accrued to one of the enterprises, but, by reason of those conditions, has not so accrued, may be included in the profit of that enterprise and taxed accordingly.",
      "verbatim": "Where: (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profit which would, but for those conditions, has accrued to one of the enterprises, but, by reason of those conditions, has not so accrued, may be included in the profit of that enterprise and taxed accordingly.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-d9acc9b73bd0ec89",
          "page": 31,
          "quote": "Where: (a) an enterprise of a Contracting State participates directly or indirectly in the management, control or capital of an enterprise of the other Contracting State, or (b) the same persons participate directly or indirectly in the management, control or capital of an enterprise of a Contracting State and an enterprise of the other Contracting State, and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profit which would, but for those conditions, has accrued to one of the enterprises, but, by reason of those conditions, has not so accrued, may be included in the profit of that enterprise and taxed accordingly.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0051"
    },
    {
      "text": "However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the dividends.",
      "verbatim": "However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the dividends.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-909bb75fe433548f",
          "page": 32,
          "quote": "However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the dividends.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0052"
    },
    {
      "text": "However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident",
      "verbatim": "However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-164f8c793a13346f",
          "page": 32,
          "quote": "However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0053"
    },
    {
      "text": "The provisions of paragraphs 1 and 2 do not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment.",
      "verbatim": "The provisions of paragraphs 1 and 2 do not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-423af8a444d88743",
          "page": 32,
          "quote": "The provisions of paragraphs 1 and 2 do not apply if the beneficial owner of the dividends, being a resident of a Contracting State, carries on business in the other Contracting State of which the company paying the dividends is a resident, through a permanent establishment situated therein, and the holding in respect of which the dividends are paid is effectively connected with such permanent establishment.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0054"
    },
    {
      "text": "The term “dividends” as used in this article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders‟ shares or other rights, not being debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.",
      "verbatim": "The term “dividends” as used in this article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders‟ shares or other rights, not being debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-fc70fa1ea7ae8b6f",
          "page": 32,
          "quote": "The term “dividends” as used in this article means income from shares, “jouissance” shares or “jouissance” rights, mining shares, founders‟ shares or other rights, not being debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0055"
    },
    {
      "text": "This paragraph does not affect the taxation of the company in respect of the profit out of which the dividends are paid.",
      "verbatim": "This paragraph does not affect the taxation of the company in respect of the profit out of which the dividends are paid.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-8fee70060564c45b",
          "page": 32,
          "quote": "This paragraph does not affect the taxation of the company in respect of the profit out of which the dividends are paid.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0056"
    },
    {
      "text": "Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except in so far as such dividends are paid to a resident of that other State or in so far as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other State, nor subject the company‟s undistributed profit, even if the dividends paid or the undistributed profit consist wholly or partly of profit or income arising in such other State.",
      "verbatim": "Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except in so far as such dividends are paid to a resident of that other State or in so far as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other State, nor subject the company‟s undistributed profit, even if the dividends paid or the undistributed profit consist wholly or partly of profit or income arising in such other State.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-4ef9c6b39fb2ee2d",
          "page": 32,
          "quote": "Where a company which is a resident of a Contracting State derives profits or income from the other Contracting State, that other State may not impose any tax on the dividends paid by the company, except in so far as such dividends are paid to a resident of that other State or in so far as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment situated in that other State, nor subject the company‟s undistributed profit, even if the dividends paid or the undistributed profit consist wholly or partly of profit or income arising in such other State.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0057"
    },
    {
      "text": "In such case, the excess part of the payments remains taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.",
      "verbatim": "In such case, the excess part of the payments remains taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-9aac87129483fd93",
          "page": 33,
          "quote": "In such case, the excess part of the payments remains taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Agreement.",
          "source": "document"
        },
        {
          "evidence_id": "ev-93bd4add7dda7f2d",
          "page": 34,
          "quote": "In such case, the excess part of the payments remains taxable according to the laws of each Contracting State, due regard being had to the other provisions of this Convention.",
          "source": "document"
        },
        {
          "evidence_id": "ev-b33495192b5ff802",
          "page": 35,
          "quote": "In such a case, the excess part of the payments remains taxable according to the law of each Contracting State, due regard being had to the other provisions of this Agreement.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0058"
    },
    {
      "text": "The provisions of paragraphs 1, 2, and 3 do not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, and the debt claim in respect of which the interest is paid is effectively connected with (a) such permanent establishment, or with (b) business activities referred to in letter (c) of paragraph 1 of article 7.",
      "verbatim": "The provisions of paragraphs 1, 2, and 3 do not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, and the debt claim in respect of which the interest is paid is effectively connected with (a) such permanent establishment, or with (b) business activities referred to in letter (c) of paragraph 1 of article 7.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-b215f09bf5194f09",
          "page": 33,
          "quote": "The provisions of paragraphs 1, 2, and 3 do not apply if the beneficial owner of the interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises, through a permanent establishment situated therein, and the debt claim in respect of which the interest is paid is effectively connected with (a) such permanent establishment, or with (b) business activities referred to in letter (c) of paragraph 1 of article 7.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0059"
    },
    {
      "text": "Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest is deemed to arise in the State in which the permanent establishment is situated.",
      "verbatim": "Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest is deemed to arise in the State in which the permanent establishment is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-9b61bca3fb052e95",
          "page": 33,
          "quote": "Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest is deemed to arise in the State in which the permanent establishment is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0060"
    },
    {
      "text": "of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the interest.",
      "verbatim": "of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the interest.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-6e8c97092de299f7",
          "page": 33,
          "quote": "of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the interest.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0061"
    },
    {
      "text": "However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the royalties.",
      "verbatim": "However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the royalties.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-31c6ca0961afb4da",
          "page": 34,
          "quote": "However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties is a resident of the other Contracting State, the tax so charged does not exceed 10 per cent of the gross amount of the royalties.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0062"
    },
    {
      "text": "The provisions of paragraphs 1 and 2 do not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with (a) such permanent establishment, or with (b) business activities referred to in letter (c) of paragraph 1 of article 7.",
      "verbatim": "The provisions of paragraphs 1 and 2 do not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with (a) such permanent establishment, or with (b) business activities referred to in letter (c) of paragraph 1 of article 7.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-88be0b1b9d47b53e",
          "page": 34,
          "quote": "The provisions of paragraphs 1 and 2 do not apply if the beneficial owner of the royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein, and the right or property in respect of which the royalties are paid is effectively connected with (a) such permanent establishment, or with (b) business activities referred to in letter (c) of paragraph 1 of article 7.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0063"
    },
    {
      "text": "Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties are deemed to arise in the State in which the permanent establishment is situated.",
      "verbatim": "Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties are deemed to arise in the State in which the permanent establishment is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-6d6c8afd1859b248",
          "page": 34,
          "quote": "Where, however, the person paying the royalties, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the liability to pay the royalties was incurred, and such royalties are borne by such permanent establishment, then such royalties are deemed to arise in the State in which the permanent establishment is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0064"
    },
    {
      "text": "However, such technical fees may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the technical fees the tax so charged shall or will not exceed 10 per cent of the gross amount of the technical fees.",
      "verbatim": "However, such technical fees may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the technical fees the tax so charged shall or will not exceed 10 per cent of the gross amount of the technical fees.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-b1f1d8ee76737c2f",
          "page": 35,
          "quote": "However, such technical fees may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the recipient is the beneficial owner of the technical fees the tax so charged shall or will not exceed 10 per cent of the gross amount of the technical fees.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0065"
    },
    {
      "text": "The provisions of paragraph 1 and 2 of this Article do not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, and the technical fees are effectively connected with such permanent establishment.",
      "verbatim": "The provisions of paragraph 1 and 2 of this Article do not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, and the technical fees are effectively connected with such permanent establishment.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-76d2f7699574eb97",
          "page": 35,
          "quote": "The provisions of paragraph 1 and 2 of this Article do not apply if the beneficial owner of the technical fees, being a resident of a Contracting State, carries on business in the other Contracting State in which the technical fees arise through a permanent establishment situated therein, and the technical fees are effectively connected with such permanent establishment.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0066"
    },
    {
      "text": "Where, however, the person paying the technical fees, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees are deemed to arise in the Contracting State in which the permanent establishment is situated.",
      "verbatim": "Where, however, the person paying the technical fees, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees are deemed to arise in the Contracting State in which the permanent establishment is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-224d0328a33b5713",
          "page": 35,
          "quote": "Where, however, the person paying the technical fees, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the obligation to pay the technical fees was incurred, and such technical fees are borne by such permanent establishment, then such technical fees are deemed to arise in the Contracting State in which the permanent establishment is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0067"
    },
    {
      "text": "Gains from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships, aircraft, or boats, are taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
      "verbatim": "Gains from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships, aircraft, or boats, are taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-6f0e45ecbfac6126",
          "page": 36,
          "quote": "Gains from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships, aircraft, or boats, are taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0068"
    },
    {
      "text": "Notwithstanding the preceding provisions of this article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.",
      "verbatim": "Notwithstanding the preceding provisions of this article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-02f37e05de100564",
          "page": 37,
          "quote": "Notwithstanding the preceding provisions of this article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0069"
    },
    {
      "text": "(b) However, such pension is taxable only in the other Contracting State if the individual is a resident of, and a national of, that other State.",
      "verbatim": "(b) However, such pension is taxable only in the other Contracting State if the individual is a resident of, and a national of, that other State.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-05169b9eabbb45a4",
          "page": 38,
          "quote": "(b) However, such pension is taxable only in the other Contracting State if the individual is a resident of, and a national of, that other State.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0070"
    },
    {
      "text": "(b) However, such salaries, wages and other similar remuneration are taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the",
      "verbatim": "(b) However, such salaries, wages and other similar remuneration are taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-c7a928bda7ca6fc3",
          "page": 38,
          "quote": "(b) However, such salaries, wages and other similar remuneration are taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that State who: (i) is a national of that State; or (ii) did not become a resident of that State solely for the purpose of rendering the",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0071"
    },
    {
      "text": "Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, is taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
      "verbatim": "Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, is taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-061b1b21ff90673a",
          "page": 39,
          "quote": "Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, is taxable only in the Contracting State in which the place of effective management of the enterprise is situated.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0072"
    },
    {
      "text": "The provisions of paragraph 1 does not apply to income, other than income from immovable property as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment.",
      "verbatim": "The provisions of paragraph 1 does not apply to income, other than income from immovable property as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-a6e762129323f51c",
          "page": 39,
          "quote": "The provisions of paragraph 1 does not apply to income, other than income from immovable property as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0073"
    },
    {
      "text": "Such deduction in either case does not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in that other State.",
      "verbatim": "Such deduction in either case does not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in that other State.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-11535092eec370b0",
          "page": 40,
          "quote": "Such deduction in either case does not, however, exceed that part of the income tax or capital tax, as computed before the deduction is given, which is attributable, as the case may be, to the income or the capital which may be taxed in that other State.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0074"
    },
    {
      "text": "Where, in accordance with any provision of this Agreement, income derived or capital owned by a resident of Mongolia [ or a Contracting State ] is exempt from tax in that State, Mongolia [ or such State ] may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.",
      "verbatim": "Where, in accordance with any provision of this Agreement, income derived or capital owned by a resident of Mongolia [ or a Contracting State ] is exempt from tax in that State, Mongolia [ or such State ] may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-6850fc5b0dc9778f",
          "page": 40,
          "quote": "Where, in accordance with any provision of this Agreement, income derived or capital owned by a resident of Mongolia [ or a Contracting State ] is exempt from tax in that State, Mongolia [ or such State ] may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0075"
    },
    {
      "text": "However, if the information is originally regarded as secret in the transmitting State it is disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to the taxes which are the subject of the Agreement.",
      "verbatim": "However, if the information is originally regarded as secret in the transmitting State it is disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to the taxes which are the subject of the Agreement.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-41d8d184b68f1c66",
          "page": 42,
          "quote": "However, if the information is originally regarded as secret in the transmitting State it is disclosed only to persons or authorities (including courts and administrative bodies) concerned with the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to the taxes which are the subject of the Agreement.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0076"
    },
    {
      "text": "However, such claims do not enjoy any priority in the requested State and cannot be recovered by imprisonment for debt of the debtor.",
      "verbatim": "However, such claims do not enjoy any priority in the requested State and cannot be recovered by imprisonment for debt of the debtor.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-e0ea2b0bdc3978bc",
          "page": 43,
          "quote": "However, such claims do not enjoy any priority in the requested State and cannot be recovered by imprisonment for debt of the debtor.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0077"
    },
    {
      "text": "However, where the claim relates to a liability to tax of a person as a non-resident of the applicant State, paragraph 2 only applies, unless otherwise agreed between the competent authorities, where the claim may no longer be contested.",
      "verbatim": "However, where the claim relates to a liability to tax of a person as a non-resident of the applicant State, paragraph 2 only applies, unless otherwise agreed between the competent authorities, where the claim may no longer be contested.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-c04eaf63a8659a08",
          "page": 43,
          "quote": "However, where the claim relates to a liability to tax of a person as a non-resident of the applicant State, paragraph 2 only applies, unless otherwise agreed between the competent authorities, where the claim may no longer be contested.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0078"
    },
    {
      "text": "The requested State is not obliged to accede to the request: (a) if the applicant State has not pursued all means available in its own territory, except where recourse to such means would give rise to disproportionate difficulty; (b) if and insofar as it considers the tax claim to be contrary to the provisions of this Agreement or of any other agreement to which both of the States are parties.",
      "verbatim": "The requested State is not obliged to accede to the request: (a) if the applicant State has not pursued all means available in its own territory, except where recourse to such means would give rise to disproportionate difficulty; (b) if and insofar as it considers the tax claim to be contrary to the provisions of this Agreement or of any other agreement to which both of the States are parties.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-345a42d32fa5cb2b",
          "page": 43,
          "quote": "The requested State is not obliged to accede to the request: (a) if the applicant State has not pursued all means available in its own territory, except where recourse to such means would give rise to disproportionate difficulty; (b) if and insofar as it considers the tax claim to be contrary to the provisions of this Agreement or of any other agreement to which both of the States are parties.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0079"
    },
    {
      "text": "This Agreement remains in force until terminated by a Contracting State.",
      "verbatim": "This Agreement remains in force until terminated by a Contracting State.",
      "topic": "Geerten M.M. Michielse June 2012",
      "severity": null,
      "evidence": [
        {
          "evidence_id": "ev-9fa3935d4df0b270",
          "page": 45,
          "quote": "This Agreement remains in force until terminated by a Contracting State.",
          "source": "document"
        }
      ],
      "confidence": 0.62,
      "extraction_method": "diagnostic_signal_sentence",
      "review_status": "unreviewed",
      "observation_id": "cr-2012-306-obs-0080"
    }
  ],
  "recommendations": [
    {
      "text": "Mongolia should hire an experienced international tax lawyer and treaty negotiator to",
      "verbatim": "Mongolia should hire an experienced international tax lawyer and treaty negotiator to",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-df7ea04f4b6499a9",
          "page": 6,
          "quote": "Mongolia should hire an experienced international tax lawyer and treaty negotiator to",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0001"
    },
    {
      "text": "Mongolia should take a more differentiated approach towards repairing its DTA",
      "verbatim": "Mongolia should take a more differentiated approach towards repairing its DTA",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-21c5f3b52f97ab44",
          "page": 6,
          "quote": "Mongolia should take a more differentiated approach towards repairing its DTA",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0002"
    },
    {
      "text": "Terminating DTAs should be used as ultimate remedy to force the other Contracting State into renegotiations if (parts of) the DTA provisions are potentially harmful for Mongolia.",
      "verbatim": "Terminating DTAs should be used as ultimate remedy to force the other Contracting State into renegotiations if (parts of) the DTA provisions are potentially harmful for Mongolia.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-5eaa3b66af4ad841",
          "page": 6,
          "quote": "Terminating DTAs should be used as ultimate remedy to force the other Contracting State into renegotiations if (parts of) the DTA provisions are potentially harmful for Mongolia.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0003"
    },
    {
      "text": "A site should not be regarded as ceasing to exist when work is temporarily discontinued.",
      "verbatim": "A site should not be regarded as ceasing to exist when work is temporarily discontinued.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-9ca2709375936595",
          "page": 8,
          "quote": "A site should not be regarded as ceasing to exist when work is temporarily discontinued.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0004"
    },
    {
      "text": "Seasonal or other temporary interruptions should be included in determining the life of a site.",
      "verbatim": "Seasonal or other temporary interruptions should be included in determining the life of a site.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-35834cb7318781c7",
          "page": 8,
          "quote": "Seasonal or other temporary interruptions should be included in determining the life of a site.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0005"
    },
    {
      "text": "The time period for deeming a construction-pe should not be less than the time period",
      "verbatim": "The time period for deeming a construction-pe should not be less than the time period",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-787fc25aa8edc3f4",
          "page": 9,
          "quote": "The time period for deeming a construction-pe should not be less than the time period",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0006"
    },
    {
      "text": "A separate article safeguarding the withholding tax on technical fees should be",
      "verbatim": "A separate article safeguarding the withholding tax on technical fees should be",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-1c810ecd22a6ca89",
          "page": 11,
          "quote": "A separate article safeguarding the withholding tax on technical fees should be",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0007"
    },
    {
      "text": "All DTAs should include provisions allowing Mongolia to levy a tax (CIT or 20 per",
      "verbatim": "All DTAs should include provisions allowing Mongolia to levy a tax (CIT or 20 per",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-d4363f0814e505d9",
          "page": 11,
          "quote": "All DTAs should include provisions allowing Mongolia to levy a tax (CIT or 20 per",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0008"
    },
    {
      "text": "The domestically used 3-months time period should not be extended to more than 6 months (to comply with international practice);",
      "verbatim": "The domestically used 3-months time period should not be extended to more than 6 months (to comply with international practice);",
      "actor": null,
      "priority": null,
      "timeframe": "6 months",
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-8cf7a5f21ffc0fb6",
          "page": 11,
          "quote": "The domestically used 3-months time period should not be extended to more than 6 months (to comply with international practice);",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0009"
    },
    {
      "text": "services in any twelve-months period should be included in DTAs.",
      "verbatim": "services in any twelve-months period should be included in DTAs.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-42a40baceb322b58",
          "page": 11,
          "quote": "services in any twelve-months period should be included in DTAs.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0010"
    },
    {
      "text": "In the DTAs with Italy and Luxemburg an additional requirement is that the shares must be held for a minimum period of 12 months before the dividend distribution.",
      "verbatim": "In the DTAs with Italy and Luxemburg an additional requirement is that the shares must be held for a minimum period of 12 months before the dividend distribution.",
      "actor": null,
      "priority": null,
      "timeframe": "12 months",
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-75422564ece3978d",
          "page": 12,
          "quote": "In the DTAs with Italy and Luxemburg an additional requirement is that the shares must be held for a minimum period of 12 months before the dividend distribution.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0011"
    },
    {
      "text": "[4] This reflects an amendment made by the OECD in 1992 to make clear that such payments are in fact lease payments that should be covered by the rules for the taxation of business profits, as defined by Article 5",
      "verbatim": "[4] This reflects an amendment made by the OECD in 1992 to make clear that such payments are in fact lease payments that should be covered by the rules for the taxation of business profits, as defined by Article 5",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-fffc4859d45d1770",
          "page": 12,
          "quote": "[4] This reflects an amendment made by the OECD in 1992 to make clear that such payments are in fact lease payments that should be covered by the rules for the taxation of business profits, as defined by Article 5",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0012"
    },
    {
      "text": "Interest payments on bank (or third party) loans should not be exempt.",
      "verbatim": "Interest payments on bank (or third party) loans should not be exempt.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-2c9b6a3576ac1003",
          "page": 14,
          "quote": "Interest payments on bank (or third party) loans should not be exempt.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0013"
    },
    {
      "text": "(regional) development banks should be exempt from tax in the source country;",
      "verbatim": "(regional) development banks should be exempt from tax in the source country;",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-7d5c094abdbc6a17",
          "page": 15,
          "quote": "(regional) development banks should be exempt from tax in the source country;",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0014"
    },
    {
      "text": "Mongolia should not initiate a differential tax rate for dividends, but may be willing",
      "verbatim": "Mongolia should not initiate a differential tax rate for dividends, but may be willing",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-54a63134112dbf57",
          "page": 15,
          "quote": "Mongolia should not initiate a differential tax rate for dividends, but may be willing",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0015"
    },
    {
      "text": "The definition of “royalty” should contain the use or right to use industrial,",
      "verbatim": "The definition of “royalty” should contain the use or right to use industrial,",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-d8be006b3ebdae55",
          "page": 15,
          "quote": "The definition of “royalty” should contain the use or right to use industrial,",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0016"
    },
    {
      "text": "The source state should be allowed to tax dividend, interest, and royalty at maximum",
      "verbatim": "The source state should be allowed to tax dividend, interest, and royalty at maximum",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-77194d08a216c4f7",
          "page": 15,
          "quote": "The source state should be allowed to tax dividend, interest, and royalty at maximum",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0017"
    },
    {
      "text": "Most DTAs do not provide guidance on the interpretation of “principally”; the DTA with Singapore states explicitly that immovable property must represent more than 75 per cent of the value of the shares, whereas the DTA with the United Kingdom seems to refer to more than 50 per cent.",
      "verbatim": "Most DTAs do not provide guidance on the interpretation of “principally”; the DTA with Singapore states explicitly that immovable property must represent more than 75 per cent of the value of the shares, whereas the DTA with the United Kingdom seems to refer to more than 50 per cent.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-499c5c34fbb94d67",
          "page": 16,
          "quote": "Most DTAs do not provide guidance on the interpretation of “principally”; the DTA with Singapore states explicitly that immovable property must represent more than 75 per cent of the value of the shares, whereas the DTA with the United Kingdom seems to refer to more than 50 per cent.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0018"
    },
    {
      "text": "The requirement that the value of immovable property should represent more than 75 per cent of the value of the shares in the DTA with Singapore, however, limits the possibility of Mongolia to execute its domestic taxing right.",
      "verbatim": "The requirement that the value of immovable property should represent more than 75 per cent of the value of the shares in the DTA with Singapore, however, limits the possibility of Mongolia to execute its domestic taxing right.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-76f84fe85e0ac271",
          "page": 16,
          "quote": "The requirement that the value of immovable property should represent more than 75 per cent of the value of the shares in the DTA with Singapore, however, limits the possibility of Mongolia to execute its domestic taxing right.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0019"
    },
    {
      "text": "DTA provision does not explicitly states that the value of such assets must be taken into account, part of the domestic taxing right is not safeguarded, and consequently a smaller part of the capital gains can be taxed in Mongolia.",
      "verbatim": "DTA provision does not explicitly states that the value of such assets must be taken into account, part of the domestic taxing right is not safeguarded, and consequently a smaller part of the capital gains can be taxed in Mongolia.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-6a1341666d854809",
          "page": 17,
          "quote": "DTA provision does not explicitly states that the value of such assets must be taken into account, part of the domestic taxing right is not safeguarded, and consequently a smaller part of the capital gains can be taxed in Mongolia.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0020"
    },
    {
      "text": "It should be made clear that immovable property—for the purpose of this provision—",
      "verbatim": "It should be made clear that immovable property—for the purpose of this provision—",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-806bae1d86fdf4dc",
          "page": 18,
          "quote": "It should be made clear that immovable property—for the purpose of this provision—",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0021"
    },
    {
      "text": "Mongolia should include a provision in its DTAs that reserves its right to tax capital",
      "verbatim": "Mongolia should include a provision in its DTAs that reserves its right to tax capital",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-6c0df0e06d72b859",
          "page": 18,
          "quote": "Mongolia should include a provision in its DTAs that reserves its right to tax capital",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0022"
    },
    {
      "text": "Incentives in the form of exemption to promote foreign direct investment and/or to promote national economic goals have proven not effective and should not be supported.",
      "verbatim": "Incentives in the form of exemption to promote foreign direct investment and/or to promote national economic goals have proven not effective and should not be supported.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-8758728c76892927",
          "page": 19,
          "quote": "Incentives in the form of exemption to promote foreign direct investment and/or to promote national economic goals have proven not effective and should not be supported.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0023"
    },
    {
      "text": "Mongolia should provide its residents under DTAs—as it does in its domestic",
      "verbatim": "Mongolia should provide its residents under DTAs—as it does in its domestic",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-165fec93f5467663",
          "page": 20,
          "quote": "Mongolia should provide its residents under DTAs—as it does in its domestic",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0024"
    },
    {
      "text": "Mongolia should refrain from including “tax sparing” provisions.",
      "verbatim": "Mongolia should refrain from including “tax sparing” provisions.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-28a094d70168ecc7",
          "page": 20,
          "quote": "Mongolia should refrain from including “tax sparing” provisions.",
          "source": "document"
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      ],
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      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0025"
    },
    {
      "text": "None of the DTAs, however, provides any indication of the content of “beneficial ownership” (neither do the UN and OECD Models), meaning that— according to Article 3, paragraph 2 of the UN Model—the domestic interpretation should be followed.",
      "verbatim": "None of the DTAs, however, provides any indication of the content of “beneficial ownership” (neither do the UN and OECD Models), meaning that— according to Article 3, paragraph 2 of the UN Model—the domestic interpretation should be followed.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-af19a75da88cc822",
          "page": 20,
          "quote": "None of the DTAs, however, provides any indication of the content of “beneficial ownership” (neither do the UN and OECD Models), meaning that— according to Article 3, paragraph 2 of the UN Model—the domestic interpretation should be followed.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0026"
    },
    {
      "text": "Mongolia should develop a limitation-on-benefit (or anti treaty shopping) provision",
      "verbatim": "Mongolia should develop a limitation-on-benefit (or anti treaty shopping) provision",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-1a6377bf318b4873",
          "page": 21,
          "quote": "Mongolia should develop a limitation-on-benefit (or anti treaty shopping) provision",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0027"
    },
    {
      "text": "Mongolia should include in its DTAs only a provision exempting scholarships,",
      "verbatim": "Mongolia should include in its DTAs only a provision exempting scholarships,",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-3a68a0ab8b4e72bf",
          "page": 22,
          "quote": "Mongolia should include in its DTAs only a provision exempting scholarships,",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0028"
    },
    {
      "text": "Such payments should follow the general rules for employment income (Article 15 UN Model).",
      "verbatim": "Such payments should follow the general rules for employment income (Article 15 UN Model).",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-ae6cd24c7fdd2db9",
          "page": 22,
          "quote": "Such payments should follow the general rules for employment income (Article 15 UN Model).",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0029"
    },
    {
      "text": "The exemption for remuneration paid to teachers and professors should be abolished",
      "verbatim": "The exemption for remuneration paid to teachers and professors should be abolished",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-3cbfd222361f0d5b",
          "page": 22,
          "quote": "The exemption for remuneration paid to teachers and professors should be abolished",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0030"
    },
    {
      "text": "Typically the mutual agreement procedure must be requested within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the DTA.",
      "verbatim": "Typically the mutual agreement procedure must be requested within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the DTA.",
      "actor": null,
      "priority": null,
      "timeframe": "3 years",
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-f4eb01425d363c03",
          "page": 22,
          "quote": "Typically the mutual agreement procedure must be requested within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the DTA.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0031"
    },
    {
      "text": "[10] In the DTAs with Malaysia, Singapore, and United Kingdom this income is limited to a certain amount, whereas in the DTAs with Austria and Turkey the services performed should not exceed the aggregate of 183 days in a calendar year.",
      "verbatim": "[10] In the DTAs with Malaysia, Singapore, and United Kingdom this income is limited to a certain amount, whereas in the DTAs with Austria and Turkey the services performed should not exceed the aggregate of 183 days in a calendar year.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-5388ac45bbffa803",
          "page": 22,
          "quote": "[10] In the DTAs with Malaysia, Singapore, and United Kingdom this income is limited to a certain amount, whereas in the DTAs with Austria and Turkey the services performed should not exceed the aggregate of 183 days in a calendar year.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0032"
    },
    {
      "text": "Future DTAs should contain the phrase that “any agreement reached will be",
      "verbatim": "Future DTAs should contain the phrase that “any agreement reached will be",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-de01d8472be828f4",
          "page": 23,
          "quote": "Future DTAs should contain the phrase that “any agreement reached will be",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0033"
    },
    {
      "text": "If agreement is reached between the competent authorities to eliminate international double taxation, domestic law should allow the appropriate action to implement this agreement.",
      "verbatim": "If agreement is reached between the competent authorities to eliminate international double taxation, domestic law should allow the appropriate action to implement this agreement.",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-9d8f2b72835a5671",
          "page": 23,
          "quote": "If agreement is reached between the competent authorities to eliminate international double taxation, domestic law should allow the appropriate action to implement this agreement.",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0034"
    },
    {
      "text": "In its domestic legislation, Mongolia should waive the statute of limitation in all cases",
      "verbatim": "In its domestic legislation, Mongolia should waive the statute of limitation in all cases",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-6d87aef7c38b039e",
          "page": 23,
          "quote": "In its domestic legislation, Mongolia should waive the statute of limitation in all cases",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0035"
    },
    {
      "text": "DTAs should include an exchange of information provision in accordance with the",
      "verbatim": "DTAs should include an exchange of information provision in accordance with the",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-a83d05ede5e75db7",
          "page": 24,
          "quote": "DTAs should include an exchange of information provision in accordance with the",
          "source": "document"
        }
      ],
      "confidence": 0.65,
      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0036"
    },
    {
      "text": "Mongolia should strive to implement a provision that allows it to request assistance",
      "verbatim": "Mongolia should strive to implement a provision that allows it to request assistance",
      "actor": null,
      "priority": null,
      "timeframe": null,
      "report_paragraph": null,
      "section": "Geerten M.M. Michielse June 2012",
      "evidence": [
        {
          "evidence_id": "ev-bd57b4671ab6d1d0",
          "page": 24,
          "quote": "Mongolia should strive to implement a provision that allows it to request assistance",
          "source": "document"
        }
      ],
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      "extraction_method": "explicit_recommendation_modal",
      "review_status": "unreviewed",
      "recommendation_type": "normative_modal_candidate",
      "explicitness": "implicit_candidate",
      "confidence_tier": "medium",
      "in_conservative_set": false,
      "recommendation_id": "cr-2012-306-rec-0037"
    },
    {
      "text": "The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.",
      "verbatim": "The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.",
      "actor": null,
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}