| Abstract |
Bilateral income tax treaties do not always operate effectively in situations where more than two states are involved. These situations are known as "triangular cases" and they typically arise where a person who is resident in two states for tax purposes (a dual resident), or a person who is resident in one state and has a permanent establishment ("PE") in another state, has dealings with a resident of a third state. This thesis explores the issues presented by the application of bilateral tax treaties in triangular cases and discusses potential solutions to those issues.
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