The International Tax Regime and the BRIC World: Elements for a Theory

Abstract

The global economy’s centre of gravity is shifting. Emerging and developing countries have been contributing over 50% of the global GDP since the onset of the 21st century, which is unprecedented since the Industrial Revolution. This article offers the first analysis of the creeping convergence of the BRIC world (i.e. Brazil, Russia, India and China) with global legal standards in a key area of International Law: the International Tax Regime (ITR). The ITR is a legal technology fundamentally designed by the League of Nations in the 1920s, when the BRICs played no relevant role. This article proposes a theory that aims to illuminate the core driving forces of the on-going trend towards global convergence in this area of International Law from both the static and dynamic dimensions. It is grounded on the logic of two-sided platforms.

Keywords: International Taxation, Globalisation, BRICS, Transfer Pricing