International Taxation Official

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

UN Model Tax Convention : Provides more taxing rights to "source" (developing) countries. : 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 : : Designed to prevent taxpayers from deferring tax

: Countries tax their residents on worldwide income , regardless of where it is earned. The primary goal is to allocate taxing rights

OECD Model Tax Convention : Favors capital-exporting (developed) countries.

: Some countries use a territorial system , exempting certain foreign-source income from domestic tax entirely. Transfer Pricing :

: Countries tax income generated within their borders , regardless of the taxpayer's residence. Mitigating Double Taxation :