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Interpretation 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)

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References

2018Dual Residence of Companies under Tax Treaties37 cited
1999The relationship between the mutual agreement procedure and internal law33 cited
2020A Court of Specialists26 cited
2011WHY DO DUTCH AND UK JUDGES CITE FOREIGN LAW?23 cited
2020Tax Treaty Interpretation – A Response to John Avery Jones18 cited
2013Some Thoughts on Convergence and Tax Treaty Interpretation16 cited
2018Confronting Conflicts of Qualification in Tax Treaty Law: The Principle of Common Interpretation and the New Approach Revisited13 cited

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2022The OECD/G20 Global Minimum Tax and Dispute Resolution: A Workable Solution Based on Article 25(3) of the OECD Model, the Principle of Reciprocity and the GloBE Model Rules10 cited

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