Triangular (Three-Angled) Situations in International Taxation and Challenges of Their Resolution

The article describes the classical types of triangular cases in international taxation and outlines possible ways to eliminate multiple juridical taxation in each triangular case. The authors provide arguments in favour of the thesis that bilateral tax treaties do not effectively resolve double juridical taxation in triangular cases. The article presents relevant provisions of the OECD Model Tax Convention as amended in 2017, aimed at preventing the abuse of tax agreement benefits by a taxpayer in a triangular case.