Tax Treaty Interpretation in Light of the Vienna Convention on the Law of Treaties

Tax Treaty Interpretation in Light of the Vienna Convention on the Law of Treaties is a book providing an in-depth analysis of the impact of the Vienna Convention on the Law of Treaties (VCLT) on interpreting and applying tax treaties. Despite the pivotal role of the VCLT in guiding treaty interpretation across various fields of international law, its application to tax treaties has received relatively little attention in academic literature. The complexity of cross-border taxation and the growing significance of tax treaties in international commerce and investment impact the increasing demand for a more thorough comprehension of the principles governing tax treaty interpretation.

This exhaustive book comprises the following topics:

• the ordinary meaning, special meaning, and tax treaty interpretation;
• good faith and tax treaty interpretation;
• the interpretation of tax treaty terms in its context;
• subsequent agreements, subsequent practice, and tax treaty interpretation;
• authentic languages and tax treaty interpretation;
• customary international law and tax treaty interpretation; and
• the relation between Article 3 (2) OECD Model (2017) and the Interpretation Rules of the Vienna Convention on the Law of Treaties.

This book aims to alleviate this deficiency by providing a comprehensive analysis of the VCLT’s influence on tax treaty interpretation, thereby contributing to a more informed and nuanced understanding of this crucial aspect of international tax law.