Interpretative Treaty Override, Breach of Confidence and the Gradual Erosion of the Importance of Tax Treaties

Journal
Brazil; France; International; United States
Bulletin for International Taxation 2015 (Volume 69), No. 1
This article addresses interpretative treaty override and its consequences for long-standing treaty networks. In particular, it reconciles the theory underlying tax treaties and the issues arising from Brazilian, French and US treaty practice to assess the effects of intentional misinterpretations and the reliance that taxpayers can place on treaty provisions.