International double taxation: general reflections on jurisdictional principles, model tax conventions and Argentina's experience

This article examines the jurisdictional principles of source taxation and taxation of worldwide income and the different approaches taken by capital-importing and capital-exporting countries. The article explains the reasons that justify exclusive source taxation and looks at the criterion of worldwide income in the OECD Model Tax Convention and the UN Model Convention. The article also provides an overview of Argentina's income tax and describes Argentina's experience in negotiating comprehensive tax treaties.