Citation: 2C_498/2013 E. 5.6.1

5.6.1. Der Zweck von Doppelbesteuerungsabkommen liegt zwar schwergewichtig, aber nicht ausschliesslich auf der Vermeidung der doppelten Besteuerung: "The terms of a tax treaty must be given their ordinary meaning in the context of the treaty as a whole, including its object and purpose. The primary purpose of a tax treaty [is] to avoid international juridical double taxation, in order to faciliate the international exchange of goods, services, capital, technology and persons. However, tax treaties do not deal exclusively with the elimination of double taxation, but also address such other issues as the prevention of fiscal evasion through the exchange of information and the assistance in the collection of taxes, as well as the elimination of discriminatory taxation. [...] The object and purpose of a tax treaty are relative to the text of the treaty and can only be given effect in so far as this does not do violence to its actual terms. Therefore, the application of any teleological principles of interpretation that require that a treaty is always given it's maximum effect in order to ensure the achievement of its underlying objects and purposes would undermine the primacy of the text and is, therefore, not in accordance with article 31 and 32 Vienna Convention on the Law of Treaties" (Frank Engelen, Interpretation of Tax Treaties under International Law, 2004, S. 428 f.).