Interpretation of "is" in tax treaties determines when OECD membership triggers treaty benefits under domestic implementation rules.

Interpretation of the term "is" in DTAAs is context-dependent: although generally present in signification, its temporal application must be determined from the treaty text and purpose. Applied to OECD membership, the operative moment for eligibility to treaty benefits depends on when the DTAA relationship produces the relevant legal consequence, and this assessment must be reconciled with the domestic requirement for legislative action or notification for treaty enforceability.

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