Credit versus exemption under domestic tax law and treaties

In this contribution the credit and exemption methods are analysed with a focus on domestic tax law as well as international tax law. The contribution focuses on the international tax policy aspects and constitutional aspects of credit and exemption, on the history of tax treaties with regard to credit and exemption as well as on the OECD Model Convention and its Commentaries. The credit and exemption methods in tax treaty negotiation are also examined, as well as their relation with the principle of non-aggravation and the WTO