When Does &#145;the Context Otherwise Require&#146; in Article 3 of the OECD Model Convention?

Rafael Tena Castro

When Does ‘the Context Otherwise Require’ in Article 3 of the OECD Model Convention? - Intertax View When Does ‘the Context Otherwise Require’ in Article 3 of the OECD Model Convention? by - Intertax When Does ‘the Context Otherwise Require’ in Article 3 of the OECD Model Convention? 42 11

This article focuses on the interpretation of tax treaties and, particularly, the expression 'unless the context otherwise requires' comprised in Article 3 of the OECD Model Convention. In the hopes of providing certainty in double tax cross-border transactions, the chapters of this article explore the applicable provisions, relevant case law and subsequent legal consequences facing these kinds of international tax issues.

Intertax