The observations on the OECD Commentaries in the interpretation of tax treaties

This article examines the role and effect of the observations on the OECD Commentaries in the interpretation of tax treaties. The article considers unilateral interpretative declarations under general international law, observations on the Commentaries and unilateral declarations, implied reiteration of the observation at the time a bilateral treaty is concluded, and the other state's reaction to the observation when the treaty is concluded.