The role and status of the OECD commentaries in tax treaty practice have equally been explored on numerous occasions, both at IFA Congresses and during branch meetings.
In recent years, however, tax treaty interpretation has faced new challenges. On the one hand, the emergence of new international standards and rules has prompted novel interpretative questions. On the other hand, court decisions dealing with tax treaty interpretation continue to be on the rise. Finally, as the principles of tax treaty interpretation evolve, their relationship with those of general international law requires increased attention.
This book revisits the fundamental principles of interpretation of tax treaty law and provides guidance in order to facilitate and strengthen the consistency of tax treaty practice with the principles laid down in the Vienna Convention on the Law of Treaties (VCLT).