Exiting from the Obligations of a Tax Treaty: An International Framework with Diverse Practices

Journal
International; OECD
Bulletin for International Taxation 2023 (Volume 77), No. 7
This article focuses on the intention of states to withdraw from tax treaty obligations, starting with the pre-ratification period and ending with post-treaty obligations. Intentions are reviewed in the light of the general principles of international law, the Vienna Convention (1969), the OECD and UN Models, and in relation to jurisprudence.