: Countries tax their residents on worldwide income , regardless of where it is earned.
: Designed to prevent taxpayers from deferring tax on mobile income by shifting it to foreign "controlled" corporations. INTERNATIONAL TAXATION
: Allow taxpayers to reduce their domestic tax liability by the amount of taxes paid to a foreign government. : Countries tax their residents on worldwide income
UN Model Tax Convention : Provides more taxing rights to "source" (developing) countries. : INTERNATIONAL TAXATION
: Bilateral agreements that determine which country has the primary right to tax specific types of income (e.g., dividends, interest, royalties).
: Countries tax income generated within their borders , regardless of the taxpayer's residence. Mitigating Double Taxation :
OECD Model Tax Convention : Favors capital-exporting (developed) countries.