Double taxation problems in international tax agreements

Increasing capital movements with the international economic and commercial relations that occurred with the globalization process, has revealed new taxation problems between states in the international arena. After the Second World War, economic, technological and financial developments exceeded the borders of the country and increased the relations of states with each other. The transgression of national borders has led states to the instinct of protecting their political borders and interests, in accordance with the principle of sovereignty. The first studies on the solution of international tax problems started with the League of Nations. Increasing capital mobility and tax problems between countries have become the focus of supranational organizations such as the OECD and the United Nations, and Tax Model Agreements have been established to prevent and eliminate double taxation related to these problems. Although countries try to choose the most suitable model agreements by considering their economic and political situations in line with their own interests, states have always had problems arising from the level of development. While the OECD Model Agreement is in favor of developed countries by nature, the UN Model Agreement prioritized the interests of developing states. In this study, the concept of international double taxation and the methods and tools that can be applied nationally and internationally to prevent or eliminate the double taxation problem are examined; International tax treaties and models, which have a major impact on the solution of international double taxation, are compared. In addition, Turkey's approach to the international double taxation problem has been examined, and the "The Turkish Model" created by the principles and principles adopted by Turkey, is discuessed.