Global Tax Hubs: Theory and Evidence

69 Pages Posted: 27 Apr 2022

Date Written: April 7, 2022


This paper aims to offer a theory of global tax hubs, bringing fresh light on their strategic role in the international tax regime (ITR) during half a century (the 1960s through the 2000s). It focuses on non-G20 tax hubs as a case study. Specifically, the paper addresses two questions that have never been posed before: 1) Can the two–sided platform concept explain a core business model of global tax hubs? 2) If so, can this business model explain the disruptive impact of the global tax hub market on ITR stability? The paper uses a proxy grounded on the strategic interaction between G20 countries and non-G20 hubs in tax treaty disputes to answer both questions by means of a new dataset covering all 488 leading tax treaty cases decided by G20 courts, typically involving intermediate entities based on non-G20 hubs. These findings may be relevant to the ongoing OECD/G20 reform proposal to the ITR. It shows that market jurisdictions like G20 countries may not have the incentive to enforce the global minimum corporate tax rate (Pillar Two), so external monitoring of their behavior might be needed. The conceptual framework underlying this paper is based on antitrust law concepts, particularly the network market and the two–sided platform.

Keywords: Global Tax Hubs, Investments Hubs, International Taxation, International Tax Regime, Tax Treaty Disputes, Pillar Two, Network Market, two-sided platform, OECD Model, Transfer Pricing, Tax Treaty Disputes, Oligopolies, Low-Tax Jurisdictions

Suggested Citation

Baistrocchi, Eduardo A., Global Tax Hubs: Theory and Evidence (April 7, 2022). Available at SSRN: or

Eduardo A. Baistrocchi (Contact Author)

London School of Economics - Law School ( email )

Houghton Street
London, WC2A 2AE
United Kingdom

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