The Prohibition of Extraterritorial Taxation under Treaty Law and its Relation to Anti-Treaty Shopping Rules

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This analysis explores extraterritorial taxation in the OECD MTC and its implications on anti-treaty shopping rules.

The prohibition of extraterritorial taxation under the OECD MTC impacts dual resident corporations and dividend payments.
Extraterritorial taxation prohibitions in double taxation conventions create opportunities for optimizing withholding taxes.
Anti-treaty shopping rules generally do not apply to dividends from dual resident companies facing extraterritorial taxation.
Tax policy examines limitations on withholding tax avoidance linked to dual resident companies under current regulations.

Thomas Kollruss (2025) studied this question.

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