Amaro, Faith; Grondona, Veronica; Picciotto, Sol - 2024
Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations … are mainly hosts to MNEs. We analyse the restrictions on source taxation of services in tax treaties, particularly those … taxation of services, breaking with the residence-source dichotomy, and adopting formulary apportionment. This could be based …