The Meaning of “Liable to Tax” and the OECD Reports: Their Interaction and Ambiguous Interpretation

The concept of “liability to tax” has far-reaching consequences in treaty scenarios, extending beyond mere qualification as a “resident of a Contracting State”. In this article, the author addresses the effect that “liability to tax” has on entitlement to treaty benefits in light of the OECD Partnership Report and other OECD reports.