This article discusses the impact of a corporate governance system on the place of effective management concept. In Part 1, which was published in European Taxation 9 (2014), the authors outlined how six different European states determine, under their respective domestic tax laws, the place of effective management of a multinational company with either a one-tier or a two-tier board. Part 2 looks at how they interpret the term "place of effective management" as used in tax treaties based on the OECD Model under both board structures and also includes a case study. The conclusion provides for a summary and recommendations to change either the OECD Model or Commentaries.