2008 OECD Model : place of effective management - what one can learn from the history

In the 2008 Update of the OECD Model, the Commentary on Art. 4 (Residence) changed the meaning of "place of effective management", the corporate residence tie-breaker, by deleting the sentence that had been added in 2000. This suggests that there is considerable uncertainty about the meaning of the expression. This article examines the history of the provision that is now available, which confirms that there has been uncertainty from the beginning. The article concludes that perhaps the time has come to abandon the expression.