International Taxation May 2026

: Bilateral agreements that determine which country has the primary right to tax specific types of income (e.g., dividends, interest, royalties).

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

: 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 : Bilateral agreements that determine which country has

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

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

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