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United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries

image of United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries

Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively implement double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. Primary audiences are officials of national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.

English

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Taxation of residents on foreign source income

The prescriptive rules in tax treaties for taxation of foreign source income in the residence country are more limited than those that apply to restrict source country taxing rights. This is despite the fact that the acknowledged purposes of tax treaties (elimination of double taxation and prevention of fiscal evasion) have equal relevance for both source and residence countries. The comparative lack of prescriptive rules has an important impact on the manner in which the taxation of foreign source income is administered in residence countries, with heavy reliance on domestic tax rules.

English

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