Abstract
This article examines the “object and purpose” of a tax treaty by discussing its meaning, identification and relevance based on the Vienna Convention (1969). It proposes an interpretation of the principal purpose test rule that remains within the limits of treaty wording while giving priority to the object and purpose.
Original language | English |
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Pages (from-to) | 110-126 |
Number of pages | 17 |
Journal | Bulletin for International Taxation |
Volume | 78 |
Issue number | 3 |
DOIs | |
Publication status | Published - 2024 |