The True Nature of Tax Treaties

Posted: 29 Oct 2024

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

Suggested Citation

Brauner, Yariv, The True Nature of Tax Treaties. Bulletin for International Taxation: Vol. 74 (2020), Issue 1, Pages 28-48, Available at SSRN: https://ssrn.com/abstract=5002962 or http://dx.doi.org/10.59403/3qbyckw

Yariv Brauner

Independent

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