International taxation

International taxation comprises the rules and practices countries use to tax cross-border income, transactions, and taxpayers. It addresses overlapping claims to tax and efforts to prevent avoidance and double taxation.

Connect

Tax residence: A legal connection that determines which country treats a person or entity as resident for tax purposes. Residence often gives a country broad rights to tax worldwide income.
Tax jurisdiction: A government's legal authority to impose and enforce taxes over persons, property, or activities. International tax conflicts begin when multiple governments assert jurisdiction over the same income.
Base erosion and profit shifting: Strategies that exploit gaps in tax rules to shift profits and erode taxable bases across countries. BEPS describes the cross-border planning practices international rules seek to constrain.
League of Nations model tax conventions: Early model agreements developed under the League of Nations to address international double taxation. Their work established foundational approaches later used in bilateral tax treaties.
Pillar One: The OECD-led reform framework intended to reallocate some taxing rights over large multinational groups to market jurisdictions. It addresses market-country claims that traditional physical-presence rules miss digitalized business profits.
Source of income: The rules that assign income to the country where it is earned, paid, or economically connected. Source rules let countries tax income arising within their territory.
Worldwide taxation: A system in which a country taxes its residents on income earned both domestically and abroad. Residence-based worldwide taxation can overlap with source-country taxation.
Controlled foreign corporation rules: Rules that tax certain foreign-company income currently to resident shareholders or parent companies. These rules limit deferral through controlled entities in low-tax jurisdictions.
OECD Model Tax Convention: A model treaty published by the OECD that guides many bilateral income-tax agreements. Its articles and commentary have strongly influenced treaty practice worldwide.
Tax competition: Competition among jurisdictions to attract investment or economic activity through tax rates and rules. Minimum-tax proposals seek to limit one form of competition between countries.