: Designed to prevent taxpayers from deferring tax on mobile income by shifting it to foreign "controlled" corporations.
: Some countries use a territorial system , exempting certain foreign-source income from domestic tax entirely. Transfer Pricing :
OECD Model Tax Convention : Favors capital-exporting (developed) countries.
UN Model Tax Convention : Provides more taxing rights to "source" (developing) countries. :
: Countries tax their residents on worldwide income , regardless of where it is earned.
: An OECD-led initiative to close gaps in international tax rules that allow multinational enterprises to artificially shift profits to low or no-tax locations. International business | Internal Revenue Service
