Articles 10 and 11 of the OECD Model and the Commentaries on the OECD Model (2017): When Clarifications Raise Further Doubts

Abstract

The changes made to the OECD Model and the related Commentaries throughout the years have generated doubts regarding the scope of articles 10 and 11. In particular, certain amendments to the 2017 OECD Commentary had the effect of raising uncertainties regarding the territorial scope of these provisions.