ABSTRACTThis article reviews the Supreme Court of Canada decision in The Queenv. Crown Forest Industries Ltd. as it pertains to the use of the OECD modeltax convention in the interpretation of tax treaties in Canada. Afterreviewing the decisions of the lower courts and the arguments presentedbefore the Supreme Court, the author analyzes the Supreme Court’sreasoning, particularly with respect to the question whether the OECDmodel tax convention should fall within the ambit of article 31 or article32 of the Vienna convention. The author concludes that, in the light ofthe Supreme Court of Canada decision, the OECD model tax conventionand commentary should be taken into consideration in all future courtdecisions involving the interpretation of Canada’s income tax treaties