International Taxation ❲TRUSTED❳

: Countries tax income generated within their borders , regardless of the taxpayer's residence. Mitigating Double Taxation :

UN Model Tax Convention : Provides more taxing rights to "source" (developing) countries. : INTERNATIONAL TAXATION

: 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

: Designed to prevent taxpayers from deferring tax on mobile income by shifting it to foreign "controlled" corporations. : Designed to prevent taxpayers from deferring tax

: Countries tax their residents on worldwide income , regardless of where it is earned.

OECD Model Tax Convention : Favors capital-exporting (developed) countries.

: 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