Source Versus Residence

The OECD Model Tax Convention, other treaties, and the bilateral treaties drafted in accordance with these models allocate the taxing rights between the state of source and the state of residence.  The allocation rules for income taxation are determined by Articles 6 to 21 of the OECD Model Convention.  Courts, tax administrations, and practitioners have to deal with a growing number of interpretation and application problems in connection with these rules.  The publication at hand provides an analysis of the allocation rules of the OECD Model Tax Convention and their equivalents in bilateral tax treaties and proposes possible alternatives.