International Taxation — definition?
Taxation of cross-border income and assets.
Taxable Event — role?
Triggers tax liability across borders.
Double Taxation — issue?
Same income taxed by two countries.
Tax Treaty — purpose?
Allocate rights, prevent double taxation.
Source vs Residence — difference?
Source: where income arises; Residence: taxpayer’s home country.
OECD and UN Models — roles?
Guidelines for treaties; OECD favors residence, UN favors source.
Tax Treaty Content — includes?
Definitions, scope, allocation, dispute resolution.
Tax Residency — importance?
Determines primary taxing country.
French Tax System — hierarchy?
Treaties > Domestic law > Regulations.
French Domestic Rates — individuals?
Progressive, up to 45%.
French Domestic Rates — companies?
Flat 25% corporate rate.
Double Taxation — methods to eliminate?
Credits or exemptions.
OECD Model — favor?
Residence-based taxation.
UN Model — favor?
Source-based taxation, especially for developing countries.
Tax Treaty — scope?
Income, capital, defined persons, and taxes.
Tax Residency — dual?
Resolved by tie-breaker rules in treaties.
Permanent Establishment — role?
Threshold for source taxation of business profits.
Mutual Agreement Procedure — purpose?
Resolve treaty disputes.
Pon a prueba tus conocimientos con 9 preguntas sobre International Taxation Fundamentals.
1. What does the field of 'Introduction to International Taxation' primarily refer to?
2. Which international organization developed the Model Convention that favors residence-based taxation?
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