This
Article counters the view that the OECD approach to qualification conflicts
does not resolve all cases. The letter view, which was initially submitted by
Klaus Vogel and has not been refuted until today, is based on the assumption of
a fundamental difference between distributive rules reading ‘shall be taxable only’ and those reading ‘may be taxed’. When the
interpretative principles enshrined in the Vienna Convention on the Law of
Treaties (VCLT) are applied to that therminology it transpires that the
difference is not fundamental but merely a matter of degree. This is confirmed
by the French text of the Model. Thus, the principles enshrined in Article
23(1) apply to all distributive rules, which is confirmed by the OECD
Commentary on Article 23. In consequence, the OECD approach covers all of the
qualification conflicts that are attributable to States applying different
distributive rules because of differences in their domestic laws, without
exception.