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The importance of tax treaty interpretation is at its peak in India. In recent years, the pace of the Indian jurisprudence on tax treaties has been astounding. Foreign decisions and overseas revenue rulings are being increasingly considered in India while interpreting tax treaties. The second and updated edition explains the Model Conventions with reference to, inter alia, the Indian decisions, CBDT Circulars, overseas jurisprudence, Australian Taxation Office (ATO) rulings, and Technical Explanations to the Indian treaties with US and Australia. The book provides a reference to the Model Commentaries as well as to the OECD Reports and analyses whether the UN/OECD view is in consonance with or departs from the Indian/overseas jurisprudence.
