Module 5

International tax: dual residence, double taxation and its relief, treaties, permanent establishment, transfer pricing, withholding and global minimum rules

Tax law stops at the border, but business and people do not. A freelancer who moves in March earns in two countries in the same year. A company with a subsidiary abroad sells goods to it, lends it money and licenses it a brand. Each state has a legitimate claim: the one where the person lives, and the one where the income arises. When both claim, the same income is taxed twice, which would make cross-border activity uneconomic. International tax law is the set of rules, mostly in treaties, that divides the right to tax, prevents double taxation and polices the shifting of profit to low-tax places. This module sets out the conflicts, the relief, the treaty system and the rules on companies that operate across borders.

General education on taxation law, using invented people, businesses and figures. It states common principles in simplified form and does not describe any one country’s law, which differs and changes; tax rules, rates, thresholds and deadlines are strict and local. It is not tax or legal advice. Consult a qualified adviser in the place that matters.