International double taxation is not prohibited under general international law, nor is it prevented by international law. Nevertheless, there is broad agreement that such double taxation is undesirable. As a result, both national...

Under tax treaties, the right to tax dividends is normally shared between states. This is not the case for capital gains on shares. For capital gains, it is typically either the shareholder’s state of residence or the state of the company...

Article 6(2), second sentence, of the OECD Model Tax Convention defines what is considered real property. The provision provides a broad framework for what is included. Buildings...

The tax treaty rules on dividends primarily apply to distributions received by shareholders as a return on their shares pursuant to a resolution adopted by the company's general meeting. The OECD Model Tax Convention defines the concept of dividends in Article...

Article 16 of the OECD Model Tax Convention contains a specific rule governing directors’ fees. Such remuneration may be taxed in the state where the company in respect of which the directorship is held is resident. Similar provisions are found in...

If an individual is considered tax resident in Norway under Norwegian domestic law and is also considered tax resident in another state under...