The Retroactive Effect of Changes to the Commentaries on the OECD Model
Bulletin for International Taxation, 2015 (Volume 69), No. 11, pp. 623-632
36 Pages Posted: 18 May 2016
Date Written: 1 11, 2015
This article discusses the temporal aspects of tax treaties. In particular, it focuses on whether the legitimate expectations of taxpayers are harmed when changes are made to the Commentaries on the OECD Model. How are taxpayers’ rights considered when they have already entered into a certain factual or legal position?
Keywords: international tax law, OECD Commentary, retroactive effect, tax treaties, intertemporal effects, intertemporality, legal certainty, taxpayers
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