https://www.taxtmi.com/manuals?id=2836 Interpretation of tax treaties relies on international-law principles, notably the Vienna Convention and ICJ sources, rather than domestic rules. Double Taxation Avoidance Agreements and associated instruments allocate taxing rights between residence and source jurisdictions to prevent juridical double taxation; in the absence of a treaty, domestic unilateral relief mechanisms seek to mitigate double taxation. The text differentiates juridical double taxation, where the same taxpayer is taxed by multiple states, from economic double taxation, where the same income is taxed in the hands of different persons, and notes that treaties may be limited or comprehensive in scope. en-us Wed, 07 Jun 2023 14:09:00 +0530 Wed, 07 Jun 2023 14:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=2836 Interpretation of tax treaties relies on international-law principles, notably the Vienna Convention and ICJ sources, rather than domestic rules. Double Taxation Avoidance Agreements and associated instruments allocate taxing rights between residence and source jurisdictions to prevent juridical double taxation; in the absence of a treaty, domestic unilateral relief mechanisms seek to mitigate double taxation. The text differentiates juridical double taxation, where the same taxpayer is taxed by multiple states, from economic double taxation, where the same income is taxed in the hands of different persons, and notes that treaties may be limited or comprehensive in scope. Manuals Income Tax Wed, 07 Jun 2023 14:09:00 +0530 https://www.taxtmi.com/manuals?id=2836