Zusammenfassung der Ressource
International
tax law
- How to tax (i) domestic sourced income earned by
non-residents, and (ii) foreign sourced income earned by
residents
- Objectives:
- Prevent double taxation
- Matching: reduce international mismatches
in entity and instrument characterisation
- Target base erosion: transfer pricing etc.
- Reduce the availability of (harmful)
preferential tax regimes
- Means and solutions
- DTAs (Double tax agreements)
- 1. Allocation of sole taxation rights
- 2. Country of residence allows a tax
credit or tax exemption for the
relevant amount
- OECD-efforts
- BEPS
- DTA model