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Priorities of Taxing Rights in Double Tax Treaties

November 6, 2025Ben Asmadeus

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Priorities of Taxing Rights in Double Tax Treaties
Illustration of various double tax treaty models and taxing‑rights prioritiesGambar: news.ddtc.co.id

The book Double Tax Avoidance Agreements: Guide, Interpretation, and Application (Second Edition), authored by Darussalam, Danny, and Riyhan Juli Asyir, was released in November 2025. It examines the priorities of taxing rights across various Double Tax Avoidance Agreement (DTAA) models.

Global economic integration has made the allocation of taxing rights across borders increasingly complex, making DTAAs essential tools for dividing rights between residence states (where the taxpayer is domiciled) and source states (where income is generated). The edition compares the US, OECD, UN, and ASEAN models, highlighting how each balances the interests of the two parties.

Understanding these model differences is crucial for Indonesia because each signed DTAA can shift taxing rights, affecting tax revenue and the investment climate. The analysis assists policymakers, tax advisors, and taxpayers in assessing the fiscal implications of international agreements.

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Source: DDTCNews

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