The True Nature of Tax Treaties

Journal
International; OECD
Bulletin for International Taxation 2020 (Volume 74), No. 1
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.