Tax Disputes Under Institutional Instability: Theory and Implications
Modern Law Review (2012), Volume 75, Issue 4, 547-577
32 Pages Posted: 6 Oct 2013 Last revised: 11 Jun 2021
Date Written: January 2, 2012
This article aims to offer the first structural analysis of tax disputes under institutional instability using a core element of the international tax regime as an example. It offers a theory grounded on Mancur Olson’s seminal contribution to group dynamics, the logic of collective action. It also suggests implications of this theory that might help to address key enforcement issues faced by the international tax regime in a frequent context worldwide: institutionally unstable countries.
Keywords: Tax Disputes, Institutional Instability, Transfer Pricing
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