Corporate gains as dealt with by double taxation treaties

Abstract

This thesis attempts to expound the manner by which corporate gains are dealt with in double taxation agreements. This dissertation begins with an introduction on the general issues relating to corporations and the categories of income earned by these entities. An examination into the way these classes on income are treated in the field of international taxation and treaty relief in the case of double taxation is subsequently endeavoured. In view of the fact that the fiscal regulation of income is dealt uniquely in each State, a comparative analysis in the light of the different Double Taxation Model Agreements, most commonly used is made. Emphasis is obviously laid on the provisions found in the OECD Model Convention especially since this Convention has played such a major role in the development of double taxation treaty networks world-wide.