This article asks the question what relevance do Article 19 (Government Service) and Article 28 (Members of diplomatic missions and consular posts) have in today's bilateral tax treaty system. Borne out of international courtesy, and codified in the Vienna Conventions, the fiscal immunity of governments in their foreign affairs is a well-established principle in international taxation. Articles 19 and 28 of the OECD Model Tax Convention on Income and Capital are a representation of this principle in the framework of the double taxation convention (DTC). The article focuses on the extension of these provisions in this context, and assesses the substantive value, history and recent practical trends in support thereof.
Intertax