Multilingual Tax Treaties: Interpretation, Semantic Analysis and Legal Theory
- ISBN-10
- 9087223218
- ISBN-13
- 9789087223212
- Category
- Double taxation
- Pages
- 784
- Language
- English
- Published
- 2015
- Author
- Paolo Arginelli
Description
Tax treaties are generally concluded in multiple authentic languages. This practice adds a factor that is to be taken into account when such treaties are interpreted and, in some cases, increases the complexity of that task.0 This book aims at identifying and clarifying the most common issues emerging in the interpretation of multilingual tax treaties. It suggests how an interpreter should tackle and disentangle such issues under public international law, with emphasis on the arguments to be used and the elements and items of evidence the interpreter can rely on to support his construction of the treaty. The issues of interpretation of multilingual treaties dealt with in this study may be divided between those of a general nature and those specific to multilingual tax treaties. Particular attention is paid to the interaction between the renvoi to the contracting states’ domestic laws, encompassed in article 3(2) of OECD Model-based tax treaties, and the linguistic aspects of those treaties, including their multilingualism.
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