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Confronting Conflicts of Qualification in Tax Treaty Law: The Principle of Common Interpretation and the New Approach Revisited

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References

2008The Nature and Authority of Precedent327 cited
1994The Role of the OECD Commentaries in the Interpretation of Tax Treaties86 cited
2005The relevance of foreign legal materials in U.S. constitutional cases: A conversation between Justice Antonin Scalia and Justice Stephen Breyer71 cited
1978The Uniform Interpretation of International Conventions42 cited
2016References to the OECD Commentaries in Tax Treaties: A Steady March from “Soft” Law to “Hard” Law?40 cited
2009The Interpretation of Tax Treaties: Myth and Reality27 cited
2013Some Thoughts on Convergence and Tax Treaty Interpretation16 cited
2019The Application of the OECD Model Tax Convention to Partnerships15 cited

Cited by

2021Interpretation of Tax Treaties and the Decisions of Foreign Tax Courts as a “Subsequent Practice” under Articles 31 and 32 of the Vienna Convention on the Law of Treaties (1969)12 cited

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