The main purpose here is an inquiry into the applicability of tax conventions, especially in the context of the personal scope. In other words, to whom are tax conventions applicable? That question means the first step of the application of tax conventions.In general tax conventions (treaties)...

"Bilateral tax treaties (BTT) are intended to promote foreign direct investment and foreign affiliate activity through double taxation relief. However, BTTs also typically contain provisions that facilitate sharing of tax information between countries intended to curtail tax avoidance by...