Interpretative Treaty Override, Breach of Confidence and the Gradual Erosion of the Importance of Tax Treaties
Jazam Santos
Abstract
Jazam Santos
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.
OpenAlex reports 3 citations for this work. Citation counts describe recorded attention and do not establish research quality.
A contribution statement is not available in the OpenAlex record.
Method details are not available in the OpenAlex metadata.
Findings are not separately available in the OpenAlex metadata.
Limitations are not available in the OpenAlex metadata.
Application details are not available in the OpenAlex metadata.
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