The Relationship between the OECD Multilateral Instrument and Covered Tax Agreements: Multilateralism and the Interpretation of the MLI

In this article, the author examines the relationship between the OECD Multilateral Instrument and Covered Tax Agreements focussing on the interpretational issues that consequently arise: (1) the influence of the MLI on the interpretation of CTAs; and (2) the effect of CTAs on the interpretation of the MLI.