Each state has the sovereign right to exercise jurisdiction over its own territory. However, double taxation belongs to a category that is regulated not only by national legal instruments but also by international ones. Therefore, it should be noted that the problem of preventing an unreasonable increase in the tax burden on taxpayers requires special attention in the implementation of an appropriate analysis. Double taxation was also a problem faced in the practice of the states during the past period. However, during that period, a certain practice was formed in the direction of regulating this issue. The double taxation problem is highly connected with the tax sovereignty. Tax sovereignty means that a state has the right to tax any individual or legal entity for their activity that must be taxed if there is any nexus. It is not rare in practice, for the same person to be subject to full tax liability in two or more states. Depending on the applicable laws, each of these criteria can lead to full tax liability.
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