Approaches in Interpretation of Treaty - Static vs Ambulatory

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..... aty provision. When a treaty refers to the provision of the domestic laws of a contracting state for assigning meaning to a particular term, and subsequently the domestic law is changed, then the question arises for assigning meaning to that term: Whether the treaty intended to assign the meaning which was prevailing in the domestic law of the contracting state at the date of signing the treaty ( .....

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..... not defined in the treaty shall be interpreted in accordance with the provisions of the tax laws of the Contracting State that may be applying the Convention. However, this provision is subject to one caveat and that is if the context requires interpreting the term 'otherwise', then, the meaning should be assigned accordingly. Therefore, the reference to the domestic tax law is not automatic if t .....

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