Article 29 (Territorial extension)

1. This Convention may be extended, either in its entirety or with any necessary modifications [to any part of the territory of (State A) or of (State B) which is specifically excluded from the application of the Convention or], to any State or territory for whose international relations (State A) or (State B) is responsible, which imposes taxes substantially similar in character to those to which the Convention applies. Any such extension shall take effect from such date and subject to such modifications and conditions, including conditions as to termination, as may be specified and agreed between the Contracting States in notes to be exchanged through diplomatic channels or in any other manner in accordance with their constitutional procedures.

2. Unless otherwise agreed by both Contracting States, the termination of the Convention by one of them under Article 30 shall also terminate, in the manner provided for in that Article, the application of the Convention [to any part of the territory of (State A) or of (State B) or] to any State or territory to which it has been extended under this Article.

Switzerland's non-exhaustive list of double taxation treaties based on Article 29 of the OECD Model

 CountryCorresponding to Art. 29 Deviations (this section is under construction)
 AustriaArt. 29 (German/French)
 China
 
 EU  
 FranceArt. 30 (German/French) 
 Germany
 
 Great Britain
 
 Hong-Kong
 
 India
 
 Italy
 
 Liechtensteinpending 
 Luxemburg 
 Malta
 
 NetherlandsArt. 28 (German/French/English) 
 Spain
 
 USA


Regulations - Verordnungstexte - Ordonnances


Swiss Case law - Rechtsprechung - Jurisprudence


Scholars - Lehre - Doctrine


Materialien (Botschaft - parl. Beratung) - Message et débats


Varia


Article 29 and Commentary of the UN Model Double Taxation Convention between Developed and Developing Countries

There is no corresponding article in the Commentary of the UN Model Double Taxation Convention between Developed and Developing Countries.

Commentary on Article 29 of the OECD Model Tax Convention

Extract from 2014 Commentary:
"1. Certain double taxation conventions state to what territories they apply. Some of them also provide that their provisions may be extended to other territories and define when and how this may be done. A clause of this kind is of particular value to States which have territories overseas or are responsible for the international relations of other States or territories, especially as it recognises that the extension may be effected by an exchange of diplomatic notes. It is also of value when the provisions of the Convention are to be extended to a part of the territory of a Contracting State which was, by special provision, excluded from the application of the Convention. The Article, which provides that the extension may also be effected in any other manner in accordance with the constitutional procedure of the States, is drafted in a form acceptable from the constitutional point of view of all OECD member countries affected by the provision in question. The only prior condition for the extension of a convention to any States or territories is that they must impose taxes substantially similar in character to those to which the convention applies.

2. The Article provides that the Convention may be extended either in its entirety or with any necessary modifications, that the extension takes effect from such date and subject to such conditions as may be agreed between the Contracting States and, finally, that the termination of the Convention automatically terminates its application to any States or territories to which it has been extended, unless otherwise agreed by the Contracting States."

Comments