Source Versus Residence

The OECD Model Tax Convention, other treaties, and thebilateral treaties drafted in accordance with these models allocate the taxingrights between the state of source and the state of residence. Theallocation rules for income taxation are determined by Articles 6 to 21 of theOECD Model Convention. Courts, tax administrations, and practitionershave to deal with a growing number of interpretation and application problemsin connection with these rules. The publication at hand provides an analysisof the allocation rules of the OECD Model Tax Convention and their equivalentsin bilateral tax treaties and proposes possible alternatives.