Worldwide, domicile and source taxation are two principles that advance the taxation of corporate actors in international markets/economies. Therefore, an inevitable risk for multinational enterprises that have cross-border investments/transactions is double taxation. The search for new markets with the best margins clearly implies that multinationals will continue to invest in different economies outside their country or country of origin. This makes double taxation a clear and present risk for these companies. On the basis of international trade conventions, each country is allowed to adopt laws, rules and regulations governing its trade relations with other countries in order to achieve the desired strategic objectives. An essential aspect of these trade laws is the tax legislation that governs how the income of different countries is taxed. . . .