A Summary of How Partnerships Are Taxed in Terms of International Law and Convention: An Entity or Transparent For Tax Purposes?

Abstract

This paper summarizes the international tax principles applicable to partnerships where they may be treated as transparent or entities for tax purposes. The different treatment of partnerships for tax purposes poses problems with double taxation, that can only be properly remedied through bilateral tax conventions.

Keywords: international tax, partnerships, transparent, entity, double tax convention, oecd, model convention

JEL Classification: K10, K33, K34