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of <h1>OECD and UN Model Conventions Guide Tax Treaty Negotiations: Key Commentary for International Tax Agreement Interpretation</h1> The OECD and UN Model Conventions serve as templates for negotiating tax treaties, with the OECD Model focusing on residence-based taxation and the UN Model on source-based taxation. Commentaries on these models provide authoritative guidance for interpreting tax treaties, although they are not binding. Courts frequently reference these commentaries, highlighting their significance in treaty interpretation. The OECD Commentary is widely used and respected, often cited in judicial decisions. The UN Commentary, while similar, offers different perspectives suitable for developing countries. Both commentaries are crucial aids in understanding and applying international tax agreements.
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