Tax Treaty Interpretation

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The book provides an in-depth analysis of Article 3(2) of the OECD Model Tax Convention, addressing historical debates and common misconceptions surrounding its application. It examines German case law on tax treaties and the influence of academic perspectives on the German Federal Fiscal Court's decisions. Additionally, it explores the connection between Article 3(2) and the Vienna Convention on the Law of Treaties, particularly regarding the interpretation of 'context'. The author proposes a comprehensive approach rooted in public international law principles, aiming to resolve ongoing disputes.