TAX 9869 Lecture Notes - Lecture 58: Model Treaty, Tax Treaty, Withholding Tax
Document Summary
Two themes on when a country might tax you: source: where income was earned, residency: if resident of a country, then subj to tax in that country. Taxes withholding at source: income was earned + sourced in this country so subj to tax in this country. Us 30% wh tax on us source income: us source paid to nonus/nonresi person (fc or. If there"s a treaty; then doesn"t necessarily get taxed @30% Income tax treaty: is made up of diff articles. Language//each country w/i treaty = a state within the treaty. Taxes covered in treaty generally = income taxes. Vat not included, sst, sales tax, might be some other treaties that cover this type of income. On top we have general definitions of how we define things (article 3 in the model treaty, but every article is diff) In order for a person to be eligible for treaty benefits (2 tests follow):
