International double taxation is one of the major obstacles to cross-border trade relations, as well as to the free movement of people, goods, services and capital within the framework of the European Union. The need to eliminate or mitigate international double taxation is increasingly decisive in the current international economic environment dominated by new technologies, digitalization, and increasing globalization.

When States regulate and define the distribution of taxation rights in cross-border transactions, they are thus able to attract investment, while strengthening the (economic and other) links between Contracting States.