Philip BakerPhilip Baker is a barrister and QC practising from Field Court Tax Chambers in Gray’s Inn. He was called to the bar in 1979, began practising in 1987 and took silk in 2002. He is visiting professor in international taxation at Oxford University and also a Senior Visiting Research Fellow at the Institute for Advanced Legal Studies, London University.
Tax Treaty Interpretation
Tax treaties are international treaties which must be interpreted according to international rules, as laid down in the Vienna Convention on the Law of Treaties. Furthermore, tax treaties, which are drawn up in line with the OECD Model Double Taxation Convention, contain separate interpretation guidelines in Article 3 paragraph 2 of the Model Convention. Both the content of the Vienna Convention on the Law of Treaties and the special interpretation rules of Article 3 paragraph 2 of the OECD Model Double Taxation Convention leave some room for interpretation. The course covers these problems, as well as the importance and implications of the OECD Commentary on the interpretation of bilateral tax treaties.
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