An Analysis of the Case Law on Article 3(2) of the OECD Model (2010)

Journal
Sada Garibay, M.
International; OECD
Bulletin for International Taxation 2011 (Volume 65), No. 8
FormatPDF
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40
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45
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This article analyses the meaning that the courts in different countries have given to the expression "unless the context otherwise requires" in article 3(2) of the OECD Model (2010), which has been included in many tax treaties.