Double taxation treaties – MLI – Practical example: double taxation of the same income in two countries

Double taxation treaties are used to remove the barriers that would arise if these treaties did not exist. What do I mean? We distinguish between limited and unlimited tax liability. A taxpayer who is resident in a given country is subject to an unlimited tax liability in that country, i.e. taxation on his total, global and worldwide income. However, there is also a limited tax liability. If you are not a resident of a particular country, but you earn income within its territory, that country is also entitled to levy taxes under its limited tax liability. And now you see, if in the regulations of many different countries there is both unlimited and limited tax liability, it results in the fact that if someone is a resident of one country and gets income from another country, then for this foreign income the tax authorities of 2 countries extend their hands …

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