International Taxation -

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

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

International taxation involves the rules and principles governing how income, profits, and taxable activities are taxed when they cross national borders. The primary goal is to allocate taxing rights between countries fairly while preventing double taxation. Taxing Rights & Jurisdiction : UN Model Tax Convention : Provides more taxing

: 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 INTERNATIONAL TAXATION