Income from cross-border services: Which country has the right to tax it?

A policy and economics-oriented legal analysis of double taxation conventions reveals the current challenges of taxing international services, namely achieving a compromise between conflicting interests of developed and developing countries as well as rendering the tax treatment of different service categories more coherent. Moreover, double taxation conventions need to be brought in line with today’s reality in which the economic connection of a service provider with a territory does not necessarily presuppose its physical presence.