Tax Treaties’ Interpretation and Application under the Challenges of the Digital Economy - Issues Raised by PANAMSAT v Beijing State Tax Bureau

[Extract]Tax treaties are designed to deal with double taxation on income derived from crossborder transactions. If, however, the two contracting countries do not arrive at the same conclusion with regard to the tax rights under the treaty, judicial double taxation can occur today. This note analyses a case involving China and the US, which highlights this issue.