In 2017, as a result of a BEPS project, the general anti-avoidance rule (GAAR) was included in Art. 29(9) of the OECD Model Tax Convention. Since the OECD Model Tax Convention remains one of the main instruments used for the interpretation of existing tax treaties around the world, the inclusion of GAAR directly into the Model poses a number of questions discussed among practitioners and scholars. Through the course, these questions would be closely investigated, inter alia:

• Is there a difference in the view of abuse of treaties whether the topic is analyzed from the source state or the resident state;
• The interaction of Art. 29(9) OECD Model Tax Convention with the guiding principle included in the Commentary;
• The interaction of Art. 29(9) OECD Model Tax Convention with domestic anti-avoidance rules – what is the common approach;
• The interaction of Art. 29(9) OECD Model Tax Convention with other provisions in the treaty;
• Interpretation of tax treaties in light of Art. 29(9) of the OECD Model Tax Convention;

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