The Concept of the “Object and Purpose” in Tax Treaty Law Based on the Vienna Convention (1969) and the Principal Purposes Test Rule

Journal
International; OECD
Bulletin for International Taxation 2024 (Volume 78), No. 3
This article examines the “object and purpose” of a tax treaty by discussing its meaning, identification and relevance based on the Vienna Convention (1969). It proposes an interpretation of the principal purpose test rule that remains within the limits of treaty wording while giving priority to the object and purpose.