1 성선제, "조약의 사법심사 - 미국의 경우를 중심으로" 법학연구소 20 (20): 3-36, 2009
2 이용섭, "국제조세(개정증보판)" 세경사 2012
3 Wittendorff, J., "The Object of Art. 9(1) of the OECD Model Convention: Commercial or Financial Relations" 2010
4 Wattel, P.J, "The Legal Status of the OECD Commentary and Static or Ambulatory Interpretation of Tax Treaties" 2003
5 Ward, D.A, "The Interpretation of Income Tax Treaties with Particular Reference to the Commentaries on the OECD Model" 2005
6 Vogel, K., "The Influence of the OECD Commentaries on Treaty Interpretations" IBFD Bulletin 2000
7 League of Nations, "The 1933 League of Nations Draft Bilateral Convention for the Prevention of Double Taxation"
8 League of Nations, "The 1927 League of Nations Draft Bilateral Convention for the Prevention of Double Taxation"
9 Organization for Economic Cooperation and Development, "Tax Treaty Characterization Issues Arising from E-Commerce" OECD Committee on Fiscal Affaris, the Technical Advisory Group on Treaty Characterization of Electronic Commerce Payments 2001
10 McCormack, J., "Subject I-Is There a Permanent Establishment?" 2009
1 성선제, "조약의 사법심사 - 미국의 경우를 중심으로" 법학연구소 20 (20): 3-36, 2009
2 이용섭, "국제조세(개정증보판)" 세경사 2012
3 Wittendorff, J., "The Object of Art. 9(1) of the OECD Model Convention: Commercial or Financial Relations" 2010
4 Wattel, P.J, "The Legal Status of the OECD Commentary and Static or Ambulatory Interpretation of Tax Treaties" 2003
5 Ward, D.A, "The Interpretation of Income Tax Treaties with Particular Reference to the Commentaries on the OECD Model" 2005
6 Vogel, K., "The Influence of the OECD Commentaries on Treaty Interpretations" IBFD Bulletin 2000
7 League of Nations, "The 1933 League of Nations Draft Bilateral Convention for the Prevention of Double Taxation"
8 League of Nations, "The 1927 League of Nations Draft Bilateral Convention for the Prevention of Double Taxation"
9 Organization for Economic Cooperation and Development, "Tax Treaty Characterization Issues Arising from E-Commerce" OECD Committee on Fiscal Affaris, the Technical Advisory Group on Treaty Characterization of Electronic Commerce Payments 2001
10 McCormack, J., "Subject I-Is There a Permanent Establishment?" 2009
11 Organization for Economic Cooperation and Development, "OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations" 2010
12 Organization for Economic Cooperation and Development, "OECD Model Tax Convention" 2008
13 Organization for Economic Cooperation and Development, "OECD Model Tax Convention" 2010
14 Interpretation of Tax Treaties under International Law, "Interpretation of Tax Treaties under International Law" International Bureau of Fiscal Documentation 2004
15 Vann, R., "Interpretation of Tax Treaties in New Holland" 2010
16 Avi-Yonah, R.S, "International Tax as International Law-An Analysis of the International Tax Regime" Cambridge Tax Law Series 2007
17 Vogel, K., "General Report, in IFA, Cahiers de Droit Fiscal International Volume LXXVIIIa" IFA 1993
18 Ward, D.A., "General Principles of Treaty Interpretation" IFA Canadian Branch 1977
19 Organization for Economic Cooperation and Development, "Final Version of Parts I to III of the Report on the Attribution of Profits to Permanent Establishments: Part I(General Considerations), Part II(Banks), Part III (Global Trading)" 2006
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