Régimen jurídico-tributario de las sociedades de personas a la luz de los convenios para evitar la doble imposición

Abstract

The legal configuration and the juridical-tax system of partnerships are different from one State to another in the marc of comparative law. Those differences could create, sometimes, a series of problems in the area of international taxation’s incomes obtained by this type of entities in its cross-bordered actuations, with special significance with regard to the application of the double taxation treaties. Those problems, which are exposed and studied on this work, don’t usually have a quick and easy solution.