Led by experts from across tax practice, industry and government and covering wide-ranging technical subjects across multiple tax jurisdictions, our ADIT International Tax Webinars are a great way to keep up with the latest global tax developments.
Join us for our next webinar on 9 November, where our speaker will be exploring tax treaty interpretation after BEPS, from literalism to purpose.
In this webinar, speaker Angelo Chirulli will explain how ordinary meaning, context, object and purpose work together under the Vienna Convention, and how those principles resolve real treaty disputes. Using Fowler, Royal Bank of Canada and the comparative example of Alta Energy, the session will examine domestic deeming rules, the status of the OECD Commentary and the risks of relying mechanically on treaty wording or broad anti-avoidance policy.
Angelo will also distinguish the interpretive role of the revised BEPS preamble from the operative principal purpose test, and explain why the applicable treaty text, MLI positions and effective dates matter. Worked scenarios and an original ADIT-style essay exercise will help delegates build clear, critical arguments, apply authority accurately and reach well-supported conclusions in both examination answers and practical advice.
Treaty interpretation after BEPS: from literalism to purpose
Monday 9 November | 14.00 GMT | 15.00 CET | 19.30 IST
with Angelo Chirulli
In this webinar, our speaker will cover:
- Vienna Convention principles in real disputes.
- Context, object and purpose as decisive interpretive tools.
- Why an isolated, mechanical reading of treaty terms can fail.
- Exam focus: constructing first-class treaty interpretation essays.
By the end of the session, delegates should be able to:
- Identify the treaty text and modifications applicable to the relevant payment or taxable period.
- Explain how wording, context and purpose interact under the Vienna Convention, including the separate functions of Article 32.
- Evaluate domestic reference clauses, OECD Commentary and judicial authority without overstating their effect.
- Distinguish the BEPS preamble, the PPT and the MLI, and apply each through the correct legal mechanism.
- Structure an ADIT essay around a clear position, relevant authority, critical application and a reasoned conclusion.
You can also submit questions for a live Q&A!
Access to the webinar is free.
The webinars are available to ADIT students and holders, and anyone else who is interested in international tax.