Interpreting Tax Treaties in the Light of Reservations and Opt-Ins under the Multilateral Instrument

Abstract

In this article, the author considers the implications for the interpretation of tax treaties of the reservations and options that are contained in the Multilateral Instrument. In this context, the author addresses and answers a number of specific questions relating to the interpretation of the Multilateral Instrument, Covered Tax Agreements and Non-Covered Tax Agreements.