An Analysis of the Case Law on Article 3(2) of the OECD Model (2010)

Sada Garibay, M.

An Analysis of the Case Law on Article 3(2) of the OECD Model (2010)

Journal

Author

Sada Garibay, M.

Country

International; OECD

Published Date

7 July 2011

Issue

Bulletin for International Taxation 2011 (Volume 65), No. 8

DOI

https://doi.org/10.59403/ac7ycg

Document

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This article analyses the meaning that the courts in different countries have given to the expression "unless the context otherwise requires" in article 3(2) of the OECD Model (2010), which has been included in many tax treaties.

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An Analysis of the Case Law on Article 3(2) of the OECD Model (2010)