What Is a Primary Difference Between the OECD and UN

What is a primary difference between the OECD and UN model tax treaties?

A) The UN model assumes all countries are economic equals, whereas the OECD model does not.
B) The UN model grants more taxing rights to the host country than does the OECD model when income repatriation is out of developing countries.
C) The model treaty of the UN gives more taxing rights to well-developed countries than developing countries.
D) All of the above are differences between the OECD and UN models.

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