The purpose of the thesis is to
(i) single out and clarify the most common types of issues emerging in
the interpretation of multilingual tax treaties (i.e. tax treaties
authenticated in two or more languages), and (ii) suggest how the
interpreter should tackle and disentangle such issues under public
international law, with a particular emphasis on the kinds of arguments
he should use and the kinds of elements and items of evidence he should
rely upon in order to support his construction of the treaty.
In order to address such issues, the author has developed a normative
(prescriptive) legal analysis based on modern linguistic and, more
specifically, semantic theories. However, since the purpose of the study
is to suggest how the interpreter should now tackle and disentangle
those issues, the author has also carried out a positive (prescriptive)
analysis, which highlights the generally accepted principles and rules
of treaty interpretation, in order (i) to carve out from his (non-ideal)
normative legal theory the results potentially conflicting with such
generally accepted principles and rules and (ii) to show how his
normative legal theory might be applied to solve interpretative issues
in cases where no common solution has been reached yet.Grenzen van fiscale soevereinitei
