Non-discrimination article in OECD Model Convention needs fundamental review.

The author reflects on the international tax law, focusing on Article 24 of the Organization for Economic Co-operation and Development (OECD) Model Convention, discussed at the IFA Congress in Brussels in September 2008. He argues that the non-discrimination article in OECD Model Convention needs fundamental review. The provision in Article 24 refers to nationality as the criterion to determine discrimination between taxpayers in a cross border situation.