2023 PTD 863

Case Laws / Head Notes / Paras

International tax conventions, agreements or treaties-----Interpretation----Reasons as to why treaty interpretation rules differ from domestic tax rules stated. International tax conventions or agreements or treaties are of special nature and the role of a state (being party to such a bilateral agreement) is more of implementing the terms of such agreement rather than that of interpreting the same and that too in a unilateral manner. Treaty interpretation rules differ from domestic tax rules for the following among other reasons: (a)    As International treaties, the Vienna Convention on the Law of Treaties of 23rd May 1969 (“VCLT”) governs double tax agreements. Therefore, their interpretation of based on the rules of interpretation of agreements differ from rules ...