With the rise of international trade, international taxation has become increasingly important. However, the lack of coordination among tax authorities has resulted in issues such as international double taxation and tax avoidance. To address these challenges, countries can use either unilateral measures or double tax conventions to provide relief. The OECD, US, and UN conventions, have been developed to serve as frameworks for tax treaty negotiations, providing guidance and standardization to ensure a consistent approach among trading partners.and each have their own distinct features and objectives. This thesis is divided into three chapters. The first chapter covers the basic concepts of international taxation law. The second chapter analyzes the similarities and differences between the OECD and U.S. Model Tax Conventions, with a focus on emerging challenges in the international tax system. The third chapter examines the Italy - U.S. income tax treaty and how it has been revised over time. Finally, the conclusion highlights the ongoing efforts of international organizations and national governments to combat double taxation and ensure a fair allocation of taxing rights between countries.
The Double Tax Treaty between the United States of America and Italy and its uniqueness, in the perspective of a comparison between the US and the OECD Model Tax Treaties
POSMON, ALESSANDRO
2022/2023
Abstract
With the rise of international trade, international taxation has become increasingly important. However, the lack of coordination among tax authorities has resulted in issues such as international double taxation and tax avoidance. To address these challenges, countries can use either unilateral measures or double tax conventions to provide relief. The OECD, US, and UN conventions, have been developed to serve as frameworks for tax treaty negotiations, providing guidance and standardization to ensure a consistent approach among trading partners.and each have their own distinct features and objectives. This thesis is divided into three chapters. The first chapter covers the basic concepts of international taxation law. The second chapter analyzes the similarities and differences between the OECD and U.S. Model Tax Conventions, with a focus on emerging challenges in the international tax system. The third chapter examines the Italy - U.S. income tax treaty and how it has been revised over time. Finally, the conclusion highlights the ongoing efforts of international organizations and national governments to combat double taxation and ensure a fair allocation of taxing rights between countries.| File | Dimensione | Formato | |
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https://hdl.handle.net/20.500.12608/48237