The OECD Commentary as a source of international law and the role of the judiciary

Journal
European Taxation 2006 (Volume 46), No. 5
In this article, the author considers three questions relating to whether or not the Commentary on the OECD Model Tax Convention on Income and on Capital is internationally legally binding, i.e. is the Commentary binding on the tax administration or binding on the State, binding on the judiciary and to which Commentary statement is reference being made?