El Tribunal Supremo Federal de Suiza se pronuncia sobre la relevancia de los comentarios al modelo de convenio de la OCDE

Abstract

The Swiss Federal Court had to decide on the relevance of the OECD Commentaries for tax treaty  interpretation. The Court distinguished between the version of the  Commentaries which was already available when the treaty was concluded and later versions. The version already existing at the time the treaty was concluded is highly relevant. However, the Court did not leave much room for later commentaries.