Article 3(2) of the OECD and UN Models: An International View
Journal
Country
International; OECD; United Kingdom
Published Date
Issue
Bulletin for International Taxation 2021 (Volume 75), No. 1
Document
In this article, Jonathan Schwarz sets outs views for an international interpretation of article 3(2) (General definitions) of the OECD Model by reference to the UK judicial decision in Fowler v. HMRC, in response to those expressed by John Avery Jones.