Handbook

This course offers a comprehensive exploration of Double Taxation Agreements (DTAs), focusing on their principles, application, and the models underpinning them. Through a curriculum that elucidates how DTAs function to allocate taxing rights between countries and prevent double taxation in international dealings, learners will gain insights primarily via the OECD model tax convention, with comparative analyses of mainly the United Nations model tax convention. These comparisons reveal the varied approaches to balancing the interests of a taxpayer's country of residence and the source country of income, reflecting the diverse priorities of the models' authoring organizations. Structured to cover the rationale behind DTAs, their structure, interpretation protocols, and application scope, the course delves into specific income types including business profits, passive income, personal services income, and capital gains, and addresses anti-avoidance and administrative provisions. Extensive references to real-world DTAs illustrate these concepts, ensuring that by the course's conclusion, participants will possess a thorough understanding of DTAs' global application and significance.