Double Taxation Avoidance Agreements and Their Application

Driven by globalization and the digital economy, the international tax architecture is undergoing a radical transformation. This work explores the evolution of Double Taxation Avoidance Agreements (DTAAs) from the 1920s to the present, focusing on the OECD Model Tax Convention and the revolutionary changes brought about by the Base Erosion and Profit Shifting (BEPS) project. The book provides an in-depth analysis of the anti-tax avoidance mechanisms integrated into treaties via the Multilateral Instrument (MLI), recent updates to the Permanent Establishment (PE) concept including the Authorized OECD Approach (AOA), and the taxation challenges of the digital economy, all from the perspective of the Turkish Tax System. Rather than examining treaty articles in the abstract, the book pairs them with domestic and international judicial decisions, tax rulings, and their equivalents in Turkish Corporate and Income Tax Laws, offering both a strong theoretical foundation and a highly practical application guide.