This article analyses the legal nature of the tradable allowance and provides a general overview of the treatment of the allowance in selected jurisdictions from an accounting and domestic law perspective. It focuses on the international tax aspects of tradable allowances, in particular the application of the distributive rules of the OECD Model Convention. As most of the identified problems emerge in the domestic context, the tax, accounting and legal treatment of the allowances in Hungary, the United Kingdom and the United States are addressed as a foundation for the international analysis.