Treaty Abuse, General International Law, and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS: What Can Be Achieved by Applying the Multilateral Convention That Cannot Already Be Achieved by Applying General International Law?
The concept of treaty abuse, although being of great significance to the operation of international tax treaties, is by no means peculiar to this particular branch of law. A treaty abuse doctrine exists in general international law since long. As this paper argues, current work within the OECD, and especially the existence of the recently negotiated Multilateral Convention to Implement Tax Treaty
