Abstract: The summary of this research revolves around The summary of this research revolves around the fact that the idea of ​​international tax law was only recently known after World War I, when the first bilateral agreement was concluded to avoid double taxation between contracting countries. And that taxation is based on the principle of territorial sovereignty; That is: every country has the right to impose taxes on income and activities within the scope of territorial jurisdiction; However, in light of the dominance of globalization and the spread of internationally active companies, and the entry into force of the World Trade Organization Agreement, the effectiveness of this principle has faded, which constitutes an element of pressure on the resources of developing countries that depend on taxes as a necessary source of income. It was necessary to have an international tax law that works to achieve harmony between tax legislation in different countries. The efforts of countries have culminated in the development of collective model treaties that are used as a guide to determine the tax sovereignty of different countries over incomes and capital.