Reference List and sources

Reference List (not exhaustive)
-The role of the OECD Commentary in tay treaty interpretation by Michael Lang and Florian Brugger
-Bodies of Persons by John. F. Avery Jones
-Double Taxation Conventions by Victor Uckmar
-L'intérpration des Conventions de double imposition de Jean-Marc Rivier
-The Legal Status of the OECD Commentary and Static or Ambulatory Interpretation of Tax Treaties by Peter J. Wattel and Otto Marres
-The Origins of Concepts and Expressions Used in the OECD Moedl and their Adoption by States by John F. Avery Jones et al.
-The OECD Commentary as a Source of International Law and the Role of the Judiciary by Hans Pijl
-The Attribution of Income to a Person for tax Treaty Purposes by Joanna Wheeler
-The Use and Interpretation of Tax Treaties in the Emerging World: Theory and Implications by Eduardo Baistrocchi
-The Application of Public International Rules on Treaty Interpretation to Tax Treaties by Rodrigo Garnica Soberanes
-Trusts and Double Taxation Agreements by John Prebble
-Double Taxation Conventions by Klaus Vogel (3rd edition)
-Tax Treaty Interpretation by Michael Lang
-Tax Treaty Interpretation by Michael Edwards – Ker
-Tax Treaty Issues - Current and Future Developments by C. van Raad
-Interpretation of Tax Treaties by Ian Sinclair
-The Vienna convention on the law of treaties by Ian Sinclair
-Interpretation of Double Taxation Conventions (general report) by Klaus Vogel and Rainer G. Prokisch
-The Influence of the OECD Commentaries on Treaty Interpretation by Klaus Vogel
-The Theory of the Interpretation of Tax Treaties with reference to the Dutch Prctice by Hans Pijil
-Interpretation of Tax Treaties by John F. Avery Jones et al.
-Article 3 (2) of the OECD Model Convention and the Commentary to ist Treaty Interpretation by John F. Avery Jones
-Principles to be Applied in Interpreting Tax Treaties by David Ward
-Interpretation of Tax Treaties by David Ward
-The Role of the OECD Commentaries in the Interpretation of Tax Treaties by Hugh Ault
-Report on "The Application of the OECD Model Tax Convention to Partnerships and the Interpretation of Tax Treaties" by F. Engelen and F. Pötgens
-Tax Treaty Interpretation by David Rosenbloom
-Principles of Interpretation in Internal and International Tax Law by Jean Van Houtte
-The Influence of the OECD Commentaries on Treaty Interpretation - Response to Prof. Dr. Klaus Vogel by M. Ellis
-Interpretation of Tax Treaties by E. Reimer
-Switzerland's direct and international taxation of private express trusts - with particular references to US, Canadian and New Zealand trust taxation by Robert J. Danon

 

Sources (not exhaustive)
-OECD (2008): Commentary on Model Tax Convention on Income and on Capital, Paris, 2008
-OECD (2009): The Granting of Treaty Benefits with respect to the Income of Collective Investment Vehicles, 2010
-OECD (1999): “The Application of the OECD Model Tax Convention to Partnerships”, in: Issues in International Taxation Series, vol. 6, Paris, 1999
-Vienna Convention of 23 May 1969 on The law of Treaties
-Convention of 23 April 1997 between Argentina and the Swiss Confederation for the Avoidance of Double Taxation with respect to Taxes on Income and Capital (RS 0.672.915.41)