: Bilateral agreements that determine which country has the primary right to tax specific types of income (e.g., dividends, interest, royalties).
OECD Model Tax Convention : Favors capital-exporting (developed) countries.
UN Model Tax Convention : Provides more taxing rights to "source" (developing) countries. : INTERNATIONAL TAXATION
International taxation involves the rules and principles governing how income, profits, and taxable activities are taxed when they cross national borders. The primary goal is to allocate taxing rights between countries fairly while preventing double taxation. Taxing Rights & Jurisdiction :
: Designed to prevent taxpayers from deferring tax on mobile income by shifting it to foreign "controlled" corporations. : Bilateral agreements that determine which country has
: Allow taxpayers to reduce their domestic tax liability by the amount of taxes paid to a foreign government.
: Countries tax income generated within their borders , regardless of the taxpayer's residence. Mitigating Double Taxation : : International taxation involves the rules and principles
: Countries tax their residents on worldwide income , regardless of where it is earned.