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Strategies by multinational companies to exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity.

The country where income is generated and from which it may be taxed, before any tax treaty benefits are applied.

When domestic tax law provisions of a country take precedence over the provisions of a tax treaty.

A fixed place of business that generally gives rise to income or value-added tax liability in a foreign country.

An individual who has been granted the right to live in a country indefinitely, including the right to work there, typically subject to taxation.

A tax imposed by a country on dividends paid to a non-resident of that country.

A deduction from the total amount a taxpayer owes to the government, often as a result of foreign taxes already paid.

A mechanism within a tax treaty that allows the authorities of the treaty partner countries to resolve disputes regarding the interpretation or application of the treaty.

A process by which tax authorities in two countries share relevant tax information with each other to ensure compliance and tackle tax evasion.

A provision in some tax treaties where a country agrees not to tax certain income in order to encourage foreign investment.

The practice of structuring a multinational corporation's affairs to take advantage of more favorable tax treaties available in certain jurisdictions.

The pricing of goods, services, and intangibles between related parties which can affect where and how much tax the parties pay.

An agreement between two countries that reduces the tax liability for residents and companies in each other's territories.

The position or body designated by a country’s government to oversee the administration of tax treaties and resolve issues of treaty interpretation and application.

Countries or territories that offer foreign individuals and businesses little or no tax liability, often combined with stringent secrecy laws and the absence of information exchange with other countries.

A clause in a tax treaty that restricts the benefits of the treaty to entities that meet certain criteria.

A model for countries to use when negotiating bilateral tax treaties, developed by the Organisation for Economic Co-operation and Development (OECD).

An official document issued by tax authorities that certifies an individual or entity is a tax resident in a particular country.

The principle that transactions between related parties should be conducted as if they were between unrelated parties, each acting in their own self-interest.

The country where an individual or entity is considered a resident for tax purposes and typically taxes worldwide income.

A model tax treaty specifically designed by the United Nations for developing countries, focusing on the allocation of taxing rights between source and residence countries.

Legislation designed to limit the artificial deferral of tax by using off-shore low taxed entities controlled by a tax resident in the controlling country.

The situation in which the same income is taxed by two different jurisdictions.

A person or entity that is liable to pay taxes in a country because of domicile, residence, place of management, or other similar criteria.