Article 3(2) of the OECD and UN Models: An International View
Journal
International; OECD; United Kingdom
Bulletin for International Taxation 2021 (Volume 75), No. 1
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.