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of <h1>Court Rules Domestic Law Changes Can't Alter Tax Treaty Terms; OECD Suggests Ambulatory Approach Under Article 3(2)</h1> Interpretation of tax treaties can follow a static or ambulatory approach. The static approach uses the meaning of terms as understood when the treaty was signed, while the ambulatory approach uses the meaning at the time of the treaty's application. The Delhi High Court ruled that amendments to domestic laws cannot alter treaty terms. The OECD model convention suggests using an ambulatory approach unless context dictates otherwise. Article 3(2) of the OECD Model Convention advises interpreting undefined terms using domestic tax laws, but only if the treaty context does not provide a specific meaning.
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