The Organisation for Economic Co-operation and Development (OECD) describes two kinds of double taxation agreements: economic and juridical.

Required:
Explain economic and juridical double taxation.

Economic Double Taxation:
Economic double taxation occurs when income from the same economic activity is taxed in the hands of different persons in more than one country. This typically happens when a company’s profits are taxed first at the corporate level and then taxed again as dividends in the hands of shareholders when distributed. The income is taxed twice, but in the hands of two different entities.
(2 marks)

Juridical Double Taxation:
Juridical double taxation arises when the same person is taxed on the same income by more than one jurisdiction. This occurs, for example, when a taxpayer is subject to tax in both their country of residence and the source country where the income was earned. The same income is taxed twice, but in the hands of the same taxpayer.
Juridical double taxation usually arises due to the following:
  • Source Principles or Rules
  • Residence Principles or Rules
    (2 marks)