Double tax treaty (DTT)

Roles that need it

• Tax Associate
• Transfer Pricing Analyst
• Private Banking Analyst
• Legal Counsel

Skills it belongs to

• Corporate taxation
• Legal research and regulatory interpretation

Related concepts

• Withholding tax (WHT)Withholding tax is tax deducted at source by the payer on dividends, interest or royalties paid to another person, often a non-resident. Investors claim reduced treaty rates at source or by refund. The EU FASTER Directive harmonises relief procedures and a digital tax residence certificate.
• Permanent establishment (PE)A permanent establishment is a fixed place of business, or in some cases a dependent agent, through which a company carries on business in another country. The profits attributable to it can be taxed there, so branches and people working abroad need careful review.
• Transfer pricingTransfer pricing sets the prices of transactions between entities of the same group, such as services, loans, guarantees and intangibles. Tax rules require the arm's length principle: prices independent parties would agree. OECD guidelines set methods and documentation (master file and local file).

Sources

• Council Directive (EU) 2017/1852 on tax dispute resolution mechanisms, EUR-Lex (external site) accessed 31 Oct 2026
• OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, OECD (external site) accessed 31 Oct 2026

Updated 31 Oct 2026.