Follow the Money: Why Is International Tax Bilateral?

5 Pages Posted: 10 Apr 2023

Date Written: March 26, 2023


International tax law has traditionally been built upon bilateral treaties and unilateral actions, while trade law has traditionally been multilateral and international investment law has been bilateral but with Most Favored Nation (MFN) clauses that render it effectively multilateral. This paper explores the reasons and asks whether they are still valid.

Keywords: tax law, trade law, investment law, bilateralism, multilateralism, BEPS

JEL Classification: H26

Suggested Citation

Avi-Yonah, Reuven S., Follow the Money: Why Is International Tax Bilateral? (March 26, 2023). Available at SSRN: or

Reuven S. Avi-Yonah (Contact Author)

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

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