This article studies the effect of the ECJ's decision in Saint-Gobain on international tax law and the OECD Model Convention. It first considers how the OECD Model deals with cases like Saint-Gobain, then comments on the effect of Saint-Gobain on the tax systems of the EU Member States. Finally, the article expresses the authors' view on how Saint-Gobain may represent a major force of change in the principles of international tax law and how the decision will contribute to the harmonization of direct taxation in the EU.