1. The Problems associated with the interpretation of tax treaties
2. The Approach of domestic courts in interpreting tax treaties
3. Discussion of case law on the interpretation of tax treaties
4. The status of OECD commentaries as soft law or hard law
5. The applicabilty of New commentaries to Old tax treaties ( ambulatory or static approach)
5. The application of S.31- 33 of the Vienna Convention to tax treaty interpretation
NB That the above is a guide and is not an outline and that the sources are also a guide, please explore more articles and case law as will be required
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