This book is a critical study of the issues surrounding the treaty allocation of tax powers between source & residence countries. It discusses the allocation of tax powers between the competing jurisdictional claims in an unbiased & practical way. It examines the prevailing treaty allocation rules from the perspective of developing countries & discusses the quest for developing an appropriate tax treaty model for allocating revenue between developing & developed countries. While demonstrating the inequity of the existing network of double tax treaties involving developing countries, it seeks to shift the emphasis in international discussions on the tax concerns of developing countries from double tax treaties to the need for providing assistance to developing countries to improve their enforcement & administrative capability in tax matters. As such, the book is ideal for students or tax practitioners, tax officers in developing countries & advisers on matters relating to overseas investments.