From the Avoidance of Double Taxation to the Avoidance of Double Non-Taxation: The Changing Objectives of Tax Treaties

The OECD/G20 Base Erosion and Profit Shifting Project has clarified that relief from double taxation under tax treaties does not extend to double non-taxation. This (new) objective of tax treaties is analysed from the perspective of the preamble and the amendments to the OECD Model (2017) and the related case law.