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After returning from his performances abroad, the artiste is again

confronted with taxation, because his residence country wants to tax his
foreign performance fees as part of his worldwide income. But this threat
of economic double taxation is normally relieved with financial
compensation by the residence country (tax credit or tax exemption) which
has been inserted in all bilateral tax treaties. Most countries also provide
this double tax relief unilaterally.1
In general, there are two ways to avoid double taxation:
(1) exempting foreign income from domestic taxation; and
(2) granting a credit for foreign taxes.
When the first tax treaties were concluded 100 years ago by the continental
European countries,2 it was logical for two states to distribute the taxable
earnings between themselves by allocating the tax right to only one state,
making these earnings tax exempt in the other. Until World War II, this
was the method unanimously applied by

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