International Taxation Now

: 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 international tax rules that allow multinational enterprises to artificially shift profits to low or no-tax locations. International business | Internal Revenue Service 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 their residents on worldwide income , regardless of where it is earned. : Designed to prevent taxpayers from deferring tax

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 : Requires transactions between related entities (e

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