: Some countries use a territorial system , exempting certain foreign-source income from domestic tax entirely. Transfer Pricing :
: Designed to prevent taxpayers from deferring tax on mobile income by shifting it to foreign "controlled" corporations. INTERNATIONAL TAXATION
: Bilateral agreements that determine which country has the primary right to tax specific types of income (e.g., dividends, interest, royalties). : Some countries use a territorial system ,
UN Model Tax Convention : Provides more taxing rights to "source" (developing) countries. : 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
OECD Model Tax Convention : Favors capital-exporting (developed) countries.
: An OECD-led initiative to close gaps in international tax rules that allow multinational enterprises to artificially shift profits to low or no-tax locations. International business | Internal Revenue Service