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of <h1>Tax Treaties: Allocating Tax Rights, Preventing Double Taxation, and Ensuring Fair Taxation under Article 26</h1> Tax treaties are designed to allocate taxing rights between residence and source states, focusing on tax residency, allocation of taxing rights, non-aggravation principles, tax credit mechanisms, exchange of information, and limitations on benefits. Tax residency is determined by domestic laws, influencing the allocation of taxing rights where the residence state typically has primary taxing rights. The non-aggravation principle ensures treaties do not create new tax liabilities beyond domestic laws. Tax credit mechanisms, such as the credit and exemption methods, prevent double taxation. Information exchange under Article 26 aids in tax enforcement, while limitation clauses prevent treaty abuse.
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