The Interpretation and Application of the Preamble and Article 6(1) of the OECD Multilateral Instrument in the Context of North American Tax Treaty Networks

This article examines the influence, if any, of the Preamble and article 6(1) of the OECD Multilateral Instrument, with particular focus on the extent to which they will modify the interpretation and application of the existing tax treaties in Canada, Costa Rica and Mexico.