UN Model Tax Convention : Provides more taxing rights to "source" (developing) countries. :
: Bilateral agreements that determine which country has the primary right to tax specific types of income (e.g., dividends, interest, royalties).
: Countries tax their residents on worldwide income , regardless of where it is earned. INTERNATIONAL TAXATION
: An OECD-led initiative to close gaps in international tax rules that allow multinational enterprises to artificially shift profits to low or no-tax locations. International business | Internal Revenue Service
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 : UN Model Tax Convention : Provides more taxing
: Designed to prevent taxpayers from deferring tax on mobile income by shifting it to foreign "controlled" corporations.
: Allow taxpayers to reduce their domestic tax liability by the amount of taxes paid to a foreign government. : An OECD-led initiative to close gaps in
: Requires transactions between related entities (e.g., a parent company and its foreign subsidiary) to be priced as if they were between independent parties to prevent profit shifting. Key Instruments & Models