article 3(2)
Read More
Articles
1 articles available
Jonathan Schwarz (Temple Tax Chambers; King’s College London) for
article 3(2), treaty interpretation, burden of proof, OECD Commetary, UN Commentary
November 3, 2022
Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…