The role and function of Article 1 of the OECD Model

This second of a two-part series on Art. 1 of the OECD Model Tax Convention examines the role and function of Art. 1 in relation to certain other articles of the OECD Model, namely, Arts. 8, 10(5), 11(5), 19, 20, 24, 25 and 26. This part shows that Art. 1 is not a guiding principle in granting treaty benefits in every case. Instead, Art. 1 is a corollary to the principles underlying the substantive provisions of the OECD Model, but is nevertheless an essential part of it.