Tax treaty interpretation can vary across jurisdictions, limiting reliance on foreign court decisions for uniform results. Tax treaty interpretation varies across jurisdictions, causing divergence in classification and taxation of identical income; courts may treat the same receipt as royalty or business income. Although the OECD Model has promoted development of international tax law and encouraged consideration of foreign judgments and rulings, such foreign authorities are persuasive rather than binding and may produce inconsistent outcomes, requiring careful comparative analysis when interpreting bilateral tax treaties.