Multilateral Dynamics in Bilateral Settings : Back to Realpolitik

This article attempts to shed light on the meaning of multilateral-ism in international taxation. Reconstructing multilateral-ism in international taxation, namely under the recent Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (OECD MLI), speaks about the co-existence of different layers of governance and pinpoints the tensions which exist between the progressive reaffirmation of global consensual standards, which are tailored to the needs of developed countries in favor of residence taxation, and bilateral solutions. Under this polyhedral model of tax governance, the so-called shift from bilateral-ism to multilateral-ism illustrates the symbolical aspiration of these global consensual standards to become customary international law