Interpretation of treaties requires a political-contextual approach shaping tax allocation and treaty reciprocity in double taxation cases.

Treaties imported into municipal law require a context-sensitive approach to interpretation, relying on broad principles and the general, diplomatic meaning of terms. Double taxation avoidance treaties operate as negotiated bargains to allocate taxing rights and facilitate commerce; their provisions reflect compromises and may produce asymmetrical benefits where trade and investment are unbalanced, so interpretation must account for the treaty's policy purpose and reciprocal allocation of tax.

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