The Transformation of International Tax

60 Pages Posted: 15 Apr 2020 Last revised: 14 May 2020

See all articles by Ruth Mason

Ruth Mason

University of Virginia School of Law

Date Written: April 15, 2020


The recession of 2008 precipitated a political crisis that motivated an unprecedented international project to curb corporate tax dodging. This Article argues, contrary to dominant scholarly views, that this effort transformed international tax — changing its participants, agenda and institutions, norms, and even its legal forms. Perhaps most important, efforts to close corporate tax loopholes opened a rift over the resulting revenues that threatens a hundred-year-old tax treaty framework. This Article identifies and critically evaluates these changes from the perspectives of revenue, inclusivity, legitimacy and accountability, innovation, and durability.

Keywords: BEPS, corporate tax avoidance, full tax, single tax, OECD, tax competition, fiscal fail-safes, tax, soft law, Inclusive Framework, OECD acquis

Suggested Citation

Mason, Ruth, The Transformation of International Tax (April 15, 2020). American Journal of International Law, forthcoming July 2020, Virginia Public Law and Legal Theory Research Paper No. 2020-36, Virginia Law and Economics Research Paper No. 2020-08, Available at SSRN:

Ruth Mason (Contact Author)

University of Virginia School of Law ( email )

United States

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