Journal Press India^®

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Article covers the phenomenon of international taxation with a practical example and key issues of emerging point of taxation. Plethora of practical examples on tax conflicts is considered to provide simplified version and their types of tax conflicts. Advent of technology over a period of last two decades widens the scope of doing business worldwide. Technologies provided wings to many MNE to expand their businesses worldwide. As a result various business models emerged in 21st century which focused on taking the tax benefits of various countries tax laws. The very objective of this article is provides basic instincts on international tax conflicts arising during the course of international business. Article limits its discussion only on tax conflicts without discussing the various solution adopted by various tax jurisdictions to resolve such tax conflicts. Only few countries DTAA are considered to elaborate the concepts, however there are more than 3000 DTAA are exists worldwide, which are not taken for our research article. Taxation is a sovereign right of every country to levy tax and collect it. International taxation is a tax levied on cross border transactions, by domestic law. Every country wants to tax every person and every transaction which takes place in their country. This unilateral levy of tax creates issue of double taxation in different forms like juridical double taxation, economic double taxation etc. Article throws light on various tax conflicts in an international scenario from different countries point of view evolving in double taxation. Every effort is made to clarify the different tax conflicts in detail with proper example. It is very much clear that taxes are not International and at the same time there is no separate global tax law that governs cross border transactions. Tax treaties between countries are evolved as a solution to these tax conflicts. However, article concludes how these tax treaties provided scope for emerging new concepts of double non taxation in the form of shifting their profit from high tax country to low tax countries.

Keywords

International Taxation; Tax Conflicts; Double Taxation; Source based Taxation; Residence based Taxation; Source Conflict; Residence Conflict

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