Source Versus Residence in International Tax Law

The allocation of the right to tax certain income between the state of source and the state of residence is of significant importance in the field of International Tax Law. The OECD Model Tax Convention provides for different definitions of sources of income and the principles of profit attribution. The interactions of the taxing rights of the source state and the residence state under the OECD Model Tax Convention need a close examination, undertaken in the present volume. Furthermore, EC law and its fundamental freedoms as well as recent secondary European law, such as the Savings Directive or the Interest and Royalties Directive, need to be taken into account nowadays, when analysing the allocation of taxing rights. This framework served as a basis for the analysis of recent developments in the field of International Tax Law in the present volume.