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2.4.Double Taxation Avoidance Agreements
2.4.1.The Concept of Double Taxation
Double taxation can manifest as domestic or international double taxation. Domestic…
Double taxation happens when different states with taxing authority impose similar…
Double taxation is the levying of more than one tax of the same nature on the same…
The OECD model defines double taxation as:…
“The imposition of similar taxes by two (or more) countries on the same taxpayer for the same taxable income during the same period.”…
Several definitions exist in the doctrine, all emphasizing similar points. For e…
Double taxation occurs when the same income is subject to taxation multiple times…
Double taxation or repeated taxation can result from overlapping tax claims by multiple…
Based on the OECD definition, the essential elements of double taxation are:• Taxation by two or more states,…
• Taxation of the same taxpayer,…
• Taxation within the same tax period,…
• Taxation of the same income or subject.…
All four elements must coexist for double taxation to occur.…
International double taxation emerged due to the globalization of world trade and…
Double taxation is often confused with repeated taxation, but there are significant…
“The imposition or collection of tax more than once on the same tax base during the same tax period under the application of the same tax law.”…
Double taxation, as defined above, involves taxation by two or more states, while…
The different causes of double taxation have led to two subcategories: legal international…
Legal double taxation involves the imposition of the same or similar taxes on the…
Legal double taxation requires the same taxpayer to be involved, while economic double…
The cause of legal double taxation is often the adoption of different principles…
An example of international legal double taxation would be:…
“A person residing in Country A who is a shareholder in a company located in Country B and receives dividends that are taxed in both countries” constitutes legal double taxation.…
An example of international economic double taxation would be:…
“For an investment made by an entity in Country A, if the financial leasing payment made to an entity in Country B is not allowed as an expense deduction by Country A, while Country B taxes the financial leasing income received by the entity in Country B,” this situation creates economic double taxation.…
Another example is when Germany considers the prices paid by the German branches…
2.3.2.2.From the Perspective of National Law (Turkish Legislation)
2.4.1.1.Elements of International Double Taxation
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