Taxation and non-discrimination : clarification and reconsideration by the OECD

In this article, the author considers the 2008 changes to the Commentary on Art. 24 of the OECD Model Convention (hereinafter: the OECD Model) on non-discrimination. Specifically, the author first examines the background to the changes, then the changes introduced into the 2008 OECD Model and, finally, the logic behind the changes and the concept of non-discrimination in double tax conventions.