[Verse 1] When business crosses borders wide Two countries want their tax divide But double taxation hurts the flow So treaties help the commerce grow Bilateral agreements signed with care Define which nation gets their share [Chorus] Treaty benefits, reduce and plan Withholding cuts from thirty to ten Tie-breaker rules when residence is unclear Common benefits for cross-border years Remember BEAT: Benefits, Exemptions, Allocations, Tie-breakers Treaty planning makes the path much clearer [Verse 2] Source country wants to tax the income Residence country claims it too Without a treaty, double burden Falls on taxpayers, me and you The withholding tax gets slashed in half When treaty provisions clear the path [Chorus] Treaty benefits, reduce and plan Withholding cuts from thirty to ten Tie-breaker rules when residence is unclear Common benefits for cross-border years Remember BEAT: Benefits, Exemptions, Allocations, Tie-breakers Treaty planning makes the path much clearer [Bridge] When residency's in question, tie-breakers take the stage Permanent home first, then center of life Management place for corps engaged Individual or business strife The competent authority decides When multiple tests collide [Verse 3] Dividends, interest, royalties too Get preferential treatment rates Capital gains and business profits Follow what the treaty states Foreign tax credits complement The relief that treaties represent [Chorus] Treaty benefits, reduce and plan Withholding cuts from thirty to ten Tie-breaker rules when residence is unclear Common benefits for cross-border years Remember BEAT: Benefits, Exemptions, Allocations, Tie-breakers Treaty planning makes the path much clearer [Outro] Cross-border planning needs the treaty map To avoid the double-taxation trap OECD model shows the way For international tax today
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