The 2003 revision of the OECD Commentaries on the improper use of tax treaties : a case for the declining effect of the OECD Commentaries?

Journal
Martín Jiménez, A.J.
Bulletin for International Taxation 2004 (Volume 58), No. 1
PriceUSD 45

Examines the OECD's new position on the new improper use/abuse of tax treaties introduced in the January 2003 revision of the OECD Model Tax Convention and Commentaries. First focuses on the new Commentary added to Art. 1 on the improper use of tax treaties and the Commentaries on the other articles closely related to it. Next studies the new Commentaries and changes to the OECD Model which deal with topics relating to access to tax treaties and their improper use.