Interpretation of Tax Treaties
In this article we will discuss about the interpretation of tax treaties:- 1. Interpretation under Domestic Tax Rules 2. Interpretation under the VCLT 3. Model Conventions and Commentaries 4. Other Extra-Textual Material 5. Interpretative Rule under OECD MC Article 3(2) 6. Conflicts of Qualification. Interpretation under Domestic Tax Rules: Treaty interpretation rules differ from domestic tax rules for several reasons. [...]