US EditionThe South Centre | SC & G-24 Special Issue 1, July 2025
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The South Centre | SC & G-24 Special Issue 1, July 2025
Comparison of Tax Revenue Effects of United Nations and OECD Subject to Tax Rule for G-24 and South Centre Member States By Faith Amaro and Sol Picciotto The Subject to Tax Rule (STTR) seeks to address the historical imbalance in the allocation of taxing rights under international tax treaties by introducing within existing treaties a new article which makes the restrictions on source taxation conditional on the residence jurisdiction imposing a…
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