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\u003cp\u003e\n \n\u003cbr /\u003eOne of the major objectives of tax treaties has been the avoidance of \ninternational double taxation. This is generally accomplished through the \nagreement of each country to limit, in specified situations set out in double \ntax treaties, its right to tax income earned from its territory by residents \nof another country. \n\u003c/p\u003e\n\u003cp\u003e\nThe OECD Model Tax Treaty, other model conventions, and the bilateral treaties \ndrafted in accordance with these models, allocate the taxing rights between \nthe state of source and the state of residence. The source rules for income \ntaxation are determined by Articles 6 through 21 of the OECD Model Convention. \nThese rules are the product of a rather long history and it seems difficult to \njustify the scope of some in today\u0026#8217;s world. Courts, tax administrators, and \npractitioners are confronted with a growing number of interpretation and \napplication problems. In a globalized world with ever-increasing cross-border \nstreams of income such problems command more and more attention. \n\u003c/p\u003e\n\u003cp\u003e\nThis book is designed to analyze the allocation rules of the OECD Model Tax \nConvention and its equivalents in bilateral tax treaties. The distinguished \ncontributors to the work examine the justification for these rules - as well \nas their scope \u0026#8211; and highlight the most relevant interpretation and attendant \napplication problems. In addition they\u0026#8217;ll suggest how such rules should be \nmodified and examine possible alternatives.\n\u003c/p\u003e\n\u003cp\u003e\n\n\u003c/p\u003e |
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