: Designed to prevent taxpayers from deferring tax on mobile income by shifting it to foreign "controlled" corporations.
: Requires transactions between related entities (e.g., a parent company and its foreign subsidiary) to be priced as if they were between independent parties to prevent profit shifting. Key Instruments & Models
: Some countries use a territorial system , exempting certain foreign-source income from domestic tax entirely. Transfer Pricing :
: 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.
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