The True Nature of Tax Treaties

Abstract

The international tax regime is under tremendous pressure. This lecture examines important incongruities in treaty law that have weakened the regime. It harnesses insights from public international law and a dedicated survey of treaty negotiators, and concludes that reform should include more formality, multilateral elements and an independent tax forum.

Full-text Paper: https://doi.org/10.59403/3qbyckw

Keywords: tax treaty, soft law, treaty policy, treaty interpretation, tax sovereignty, avoidance of double taxation, reciprocity principle, treaty override, tax sparing credit, harmful tax competition, multilateral tax treaty, dispute resolution