: Bilateral agreements that determine which country has the primary right to tax specific types of income (e.g., dividends, interest, royalties).
: Countries tax their residents on worldwide income , regardless of where it is earned. INTERNATIONAL TAXATION
: Some countries use a territorial system , exempting certain foreign-source income from domestic tax entirely. Transfer Pricing : : Bilateral agreements that determine which country has
OECD Model Tax Convention : Favors capital-exporting (developed) countries. INTERNATIONAL TAXATION