The Tie-Breaker Rule in Inheritance Tax Treaties: The Asymmetry of Taxing Rights by Migrants

Journal
Takahashi, M.
International; OECD
Bulletin for International Taxation 2021 (Volume 75), No. 10
FormatPDF
USD
45

There are more than 3,000 income tax treaties in the world, but fewer than 100 inheritance tax treaties. Why is the number of inheritance tax treaties so low compared to income tax treaties? This article attempts to answer this question by analysing the tie-breaker rule of inheritance tax treaties.