Vienna Convention treaty interpretation: good faith ordinary meaning approach governs application of tax treaties and aids construction. The Vienna Convention establishes principles for interpreting tax treaties, centring on Article 31's general rule: treaties are to be interpreted in good faith according to ordinary meaning in context and in light of their object and purpose, with context including text, preamble, related agreements and subsequent practice; Article 32 allows use of preparatory work when Article 31 yields ambiguity or absurdity. The Convention further affirms pacta sunt servanda, prohibits invoking domestic law to avoid treaty duties, enjoins non retroactivity absent contrary intent, defines territorial scope, and limits grounds and procedures for termination, suspension or invalidation of treaties.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Vienna Convention treaty interpretation: good faith ordinary meaning approach governs application of tax treaties and aids construction.
The Vienna Convention establishes principles for interpreting tax treaties, centring on Article 31's general rule: treaties are to be interpreted in good faith according to ordinary meaning in context and in light of their object and purpose, with context including text, preamble, related agreements and subsequent practice; Article 32 allows use of preparatory work when Article 31 yields ambiguity or absurdity. The Convention further affirms pacta sunt servanda, prohibits invoking domestic law to avoid treaty duties, enjoins non retroactivity absent contrary intent, defines territorial scope, and limits grounds and procedures for termination, suspension or invalidation of treaties.
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