31Nor, in the allocation of fiscal jurisdiction, is it unreasonable for the Member States to base their agreements on international practice and the model convention drawn up by the OECD, Article 19(1)(a) of the 1994 version of which in particular provides for recourse to the paying State principle. According to the commentary on that article, that principle is justified by ‘the rules of international courtesy and mutual respect between sovereign States’ and ‘is contained in so many of the existing conventions between OECD member countries that it can be said to be already internationally accepted’.
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