Treaty interpretation: prefer objective, contextual meaning while using purposive methods to prevent double taxation and treaty shopping. Interpretation of tax treaties prefers the objective ordinary meaning of words interpreted in context, yielding only where literal reading leads to absurdity; purposive and subjective elements (common intention and Treaty aims) inform a liberal, integrated construction giving effect to each provision, preferring reasonable, consistent meanings in light of international law, to secure effectiveness, prevent double taxation and treaty shopping, and allocate taxing rights between States.
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.
Treaty interpretation: prefer objective, contextual meaning while using purposive methods to prevent double taxation and treaty shopping.
Interpretation of tax treaties prefers the objective ordinary meaning of words interpreted in context, yielding only where literal reading leads to absurdity; purposive and subjective elements (common intention and Treaty aims) inform a liberal, integrated construction giving effect to each provision, preferring reasonable, consistent meanings in light of international law, to secure effectiveness, prevent double taxation and treaty shopping, and allocate taxing rights between States.
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