2014•Bulletin for international taxationRequires access

Interpretative Treaty Override, Breach of Confidence and the Gradual Erosion of the Importance of Tax Treaties

Jazam Santos

Open publisher page 3 citations

Abstract

This article addresses interpretative treaty override and its consequences for long-standing treaty networks. In particular, it reconciles the theory underlying tax treaties and the issues arising from Brazilian, French and US treaty practice to assess the effects of intentional misinterpretations and the reliance that taxpayers can place on treaty provisions.

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What this paper is about

This article addresses interpretative treaty override and its consequences for long-standing treaty networks. In particular, it reconciles the theory underlying tax treaties and the issues arising from Brazilian, French and US treaty practice to assess the effects of intentional misinterpretations and the reliance that taxpayers can place on treaty provisions.

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OpenAlex reports 3 citations for this work. Citation counts describe recorded attention and do not establish research quality.

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Available abstract

This article addresses interpretative treaty override and its consequences for long-standing treaty networks. In particular, it reconciles the theory underlying tax treaties and the issues arising from Brazilian, French and US treaty practice to assess the effects of intentional misinterpretations and the reliance that taxpayers can place on treaty provisions.

Key concepts: Treaty, Tax treaty, Political science, Law, Law and economics, Arms control, Tax law, Sociology

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