1. 3) explains that "the single tax principle states that income from cross-border transactions should be subject to tax once (that is;R Avi-Yonah;International Tax as International Law: An Analysis of the International Tax Regime,2007
2. V.E.1 OECD Council Recommendation on Principles concerning Transfrontier Pollution (14 Nov 74). See Basic Document V.B.7, supra
3. Article 1(2) brought a provision focused on how the "income of a resident;While Article
4. has to shoehorn a solution for transparent entities into a treaty structure that was not designed for them;The Missing Keystone of Income Tax Treaties,2012